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Mandatory Disclosure And Cooperation To Be Proposed For Commercial Item And Overseas Contractors

Client Alert | 1 min read | 04.16.08

In a hearing before the House Oversight and Government Reform Committee on April 15, 2008, the Administrator for Federal Procurement Policy indicated that he is inclined to issue a new proposed rule that would subject commercial item contracts and contracts performed overseas to mandatory disclosure to the agency inspector general when the contractor "has reasonable grounds to believe that a principal, employee, agency, or subcontractor of the [c]ontractor has committed a violation of Federal criminal law in connection with the award or performance of [a] contract or any subcontract thereunder." Such proposed rule would also modify a November 14, 2007 proposal, discussed in the linked article by C&M's Angela Styles, to mandate "[f]ull cooperation with Government agencies responsible for audit, investigation, or corrective action" for commercial item and overseas contracts.

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Client Alert | 14 min read | 03.13.26

AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems

On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities.  The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards.  The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed.  GSA requests comments by March 20, 2026....