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New FAR Requirement Forces Contractors to Examine Confidentiality Agreements

Client Alert | 1 min read | 03.03.16

On March 22, the comment period is set to close on a new rule proposed by the FAR Council that will prohibit federal dollars from going to companies that require employees or subcontractors to sign restrictive confidentiality agreements that could limit the ability of employees to report suspected fraud and abuse to the government. In a "Feature Comment" published in The Government Contractor, C&M attorneys explore the risks contractors face in light of the rule, which comes at a time of increased scrutiny from government agencies on the use of internal confidentiality agreements.

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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:...