GSA Schedule Prices No Longer Presumed Reasonable at DoD
Client Alert | less than 1 min read | 04.07.14
On March 13, 2014, DoD issued a class deviation to FAR 8.404(d) that could make orders under GSA Schedule contracts more burdensome for both contractors and DoD, directing that contracting officers can no longer rely upon GSA's determination of price reasonableness and must instead conduct their own price analysis using the techniques in FAR 15.404-1. When the award is not competitive, those price analysis techniques could include evaluation of prices charged in similar sales or, if it is the only means to determine that the price is reasonable, could even include obtaining cost data to support the pricing of these commercial contracts.
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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:
Client Alert | 4 min read | 04.18.24
Client Alert | 6 min read | 04.16.24
Navigating the AI Intellectual Property Maze - Key Points From Congressional Hearing
Client Alert | 5 min read | 04.15.24
Making the EU Courts More Efficient for Trade-Related Decisions
