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Importance of Revolving Door Review and Recordkeeping

Client Alert | less than 1 min read | 04.13.16

A recent DoD IG report called into question the reliability of DoD’s revolving door ethics opinion database, noting the database was unable to generate information required by Congress. This report suggests contractors may be the next to face inquiries and underscores the importance of proper procedures and recordkeeping when hiring former government employees.

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:...