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House Hammers Hubzone Program

Client Alert | 1 min read | 03.31.09

Following the release of a GAO Report (GAO-09-440) on March 25, 2009, finding continued fraud and abuse in the SBA's Historically Underutilized Business Zone ("HUBZone") program, members of the House Small Business Committee stated that they would consider shutting down the program if the widespread fraud was not addressed immediately. The GAO report found that 19 firms who were ineligible for the HUBZone program had received $30 million in HUBZone contracts and $187 million on all federal contracts during FY2006 and 2007, largely as a result of the SBA's lack of internal controls in identifying fraudulent designations of principal offices and failures to comply with the 35 percent residency requirement.

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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:...