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Out with the DUNS, In with the UEI: GSA Announces Transition Deadline for April 2022

Client Alert | 1 min read | 08.10.21

On July 28, 2021, the GSA shared a blog post on its outreach site, GSA Interact, announcing the final transition deadline of April 4, 2022, from using the 9-digit Data Universal Numbering System (DUNS number) to the new 12-digit alphanumeric Unique Entity ID (UEI) codes in SAM.gov.  On that date, no new DUNS numbers will be issued, and only the new UEI will be provided in SAM.gov data and reports.  All entities already registered in SAM.gov have been assigned a UEI, which is viewable in the entity registration record in SAM.gov.  Contractors should prepare their own internal systems and processes to accept the new UEI numbers and to stop using the DUNS number for federal awards processes by April 2022.

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:...