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New Reporting Requirements For Grant and Cooperative Agreement Recipients

Client Alert | 1 min read | 09.14.10

On September 14, 2010, OMB issued two regulations implementing the Federal Funding Accountability and Transparency Act of 2006 requirements applicable to recipients of federal financial assistance. The first requires (among other things) that, for any new award made after October 1, 2010, applicants and recipients of grants and cooperative agreements must register in the Central Contractor Registration ("CCR"), and the second requires (among other things) that recipients of grants and other forms of federal financial assistance must (subject to a few limitations that generally mirror those in the FAR) provide information about the recipient's executive compensation, first-tier subawards over $25,000, and subrecipients' executive compensation.

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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....