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Recovery Act CRIB Sheet For Government Contractors, Part II, The Interim FAR

Client Alert | 1 min read | 04.03.09

On March 31, 2009, the FAR Council issued extensive interim rules to implement the requirements for FAR contracts funded by the Recovery Act. Crowell & Moring has prepared a detailed analysis of each new FAR provision, including those about the Buy American Act Requirements, the onerous reporting requirements for prime and subcontractors, the Inspector General and Government Accountability Office Audit Rights and access to contractor employees, government publication requirements, and the substantial new whistleblower protections.

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:...