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DoD IG Signals Shift in FOIA Policy

Client Alert | less than 1 min read | 08.18.16

In June, the DoD IG announced that, "[i]n an effort to create greater transparency, DoD OIG will proactively redact and post reports and select administrative investigations," rather than requiring FOIA requests for them. Along with the recent amendments to FOIA, which require agencies to "make available for public inspection in an electronic format" records "that have been requested three or more times," the IG's decision is likely to increase the amount of information available to the public regarding IG reports, which in the past have included investigations of major defense programs.

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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:...