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DPAS Regs Updated and Expanded

Client Alert | less than 1 min read | 08.15.14

On August 14, 2014, Commerce's Bureau of Industry and Security issued a final rule revising the Defense Priorities and Allocations System (DPAS) Regulations. Among other changes, the final rule (1) expands the scope of DPAS coverage by adding homeland security and critical infrastructure protection/restoration activities as reasons that rated orders may be issued; (2) adds language clarifying that recipients of rated orders have delegated authority to place ratings on contracts or orders with lower-tier contractors, subcontractors, and suppliers; and (3) reduces the time for written follow-up if a party is unable to comply with a rated order. 

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...