New Rule Requires Contractors to Report Data for DoD Service Contracts in SAM
Client Alert | 1 min read | 07.09.21
On July 9, 2021, the U.S. Department of Defense (DoD) published a Final Rule to require contractors to report data in the System for Award Management (SAM) on an annual basis when they are awarded a DoD contract or task order that: (1) is valued in excess of $3 million, and (2) is for logistics management services, equipment related services, knowledge-based services, or electronics and communications services. When applicable, contractors will be required to annually report: (1) the total dollar amount invoiced for, and (2) the total number of direct labor hours expended on services performed under the contract or task order during the preceding fiscal year. The total number of direct labor hours reported to SAM should be the total of both the contractor hours and its first-tier subcontractors’ hours.
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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:
Client Alert | 4 min read | 04.18.24
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Making the EU Courts More Efficient for Trade-Related Decisions
