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DoD’s Stocking Stuffer: Defense Department Announces Proposed CMMC Pilot Programs

Client Alert | 1 min read | 12.21.20

This week, the DoD announced the first group of pilot programs under the Cybersecurity Maturity Model Certification. Although still under review, these programs will likely be among a small group to issue solicitations in FY2021 that will require a CMMC certificate to be eligible for award. The DoD expects to identify eight other programs in the coming weeks, bringing the total number of FY2021 solicitations subject to CMMC up to 15. Each program is expected to require a Level 3 certificate for primes, and either a Level 3 or Level 1 certificate for every subcontractor, with limited exceptions.

U.S. Navy

  • Integrated Common Processor
  • F/A-18E/F/ Full Mod of the SBAR and Shut Off Valve
  • DDG-51 Lead Yard Services / Follow Yard Service

U.S. Air Force

  • Mobility Air Force Tactical Data Links
  • Consolidated Broadband Global Area Network Follow-On
  • Azure Cloud Solution

Missile Defense Agency

  • Technical Advisory and Assistance Contract

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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:...

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