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Making a List, Checking it Twice: OIG Report Details Contractor Payments Under Section 3610 of the CARES Act

Client Alert | 1 min read | 12.16.20

On December 9, 2020, the Department of Defense Office of Inspector General (DoD OIG) released its Audit of Department of Defense Implementation of Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act. The audit report assesses several aspects of how the DoD has issued relief under Section 3610, including how well contracting officers have complied with guidance, issues with contractor disclosures, and common reasons for denying relief. For an in-depth summary of the report, read the full article here.

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:...