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Fair Pay and Safe Workplaces, We Hardly Knew Ye

Client Alert | less than 1 min read | 03.28.17

On March 27, 2017, President Trump signed a joint resolution under the Congressional Review Act disapproving the Fair Pay and Safe Workplaces Final Rule. Most of the rule’s requirements were put on hold in October when a U.S. district court judge in Texas granted a preliminary injunction (discussion available here); however, the rule’s paycheck transparency requirements became effective on January 1, 2017. The President’s signature will eliminate the entire rule, including the paycheck transparency requirements, relieving contractors of substantial compliance burdens associated with the FAR rules and Department of Labor Guidance implementing the EO.

Insights

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:...