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DoD's New Year's Gift: More Time to Meet Cyber Safeguarding Requirements

Client Alert | 1 min read | 12.30.15

On December 30, DoD issued an interim rule amending the DFARS Safeguarding Rule in several respects, including to provide contractors up to December 31, 2017, to comply with the security control requirements identified in DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, and detailed in NIST Special Publication 800-171, Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations. Despite the additional time to comply, within 30 days of contract award, contractors must still notify the DoD Chief Information Officer of any NIST SP 800-171 security requirements not yet implemented.

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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:...