GSA Finally Confirms that Contractors Can Opt Out of Transactional Data Reporting
Client Alert | 1 min read | 08.18.17
On Thursday, the General Services Administration formally announced that starting with the new solicitation refresh (anticipated in October 2017), participation in the Transactional Data Reporting pilot will be voluntary. Significantly, GSA has also announced that contractors that were forced into TDR (for new contract awards, option exercises, or the addition of a TDR-covered SIN) will have a one-time opportunity to opt back out of TDR. While the long-term fate of the TDR approach to pricing (which replaces the requirement for Commercial Sales Practices disclosures and Basis of Award customer tracking) remains uncertain, this announcement suggests that these long-standing approaches will not be completely eliminated any time soon.
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Client Alert | 3 min read | 04.14.26
On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded.
Client Alert | 4 min read | 04.14.26
FedRAMP Solicits Public Comment on Overhaul to Incident Communications Procedures
Client Alert | 5 min read | 04.14.26
Client Alert | 4 min read | 04.14.26


