GSA Seeks Comments on Proposed Class Deviation to Address Open "Recurrent Points of Inconsistency" in Commercial Supplier Agreements
Client Alert | 1 min read | 03.20.15
On March 20, 2015, the General Services Administration published a notice seeking comments on a proposed class deviation to the Federal Acquisition Regulation and General Services Acquisition Regulation intended to address "recurrent points of inconsistency" between Federal law and commercial supplier agreements, to establish that the FAR's commercial item terms take precedence over commercial supplier agreements, and to implement standard terms and conditions in order to minimize the need to individually negotiate agreements. GSA has provided a roadmap to all the terms and conditions customarily used by contractors in commercial supplier agreements (15 in total) that it believes conflict with Federal law; contractors have an opportunity to submit comments on this proposed class deviation on or before April 20, 2015.
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Imagine a typical morning at your retail store, hospital, or hotel—customers are arriving, staff are busy, and suddenly, federal agents from ICE appear at your front desk. The surprise is real, but panic does not have to be. Unannounced inspections conducted by Immigration and Customs Enforcement (ICE) inspectors have been occurring for years, but in recent months, ICE has ramped up inspection visits across the service sector, targeting I-9 compliance and employment records. These visits are not always dramatic raids; more often, they are routine checks that can escalate if your team is not prepared.
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