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Section 3610 of the CARES Act Extended Until March 31, 2021

Client Alert | 1 min read | 12.30.20

On Sunday, President Trump signed a combined COVID-Relief and Omnibus Spending Bill, The Consolidated Appropriations Act of 2021, which funds the Federal Government for FY 2021 and includes a variety of COVID-19-related relief measures.  Among those measures, Section 1002 of the Act extends the reimbursement period for Section 3610 of the CARES Act, which allows federal agencies to use their funds to reimburse contractors for paid leave made to employees who are unable to access the worksites and unable to telework during the pandemic. The initial reimbursement cutoff of September 30, 2020 was previously extended until December 11, 2020, and the Act further extends the period until March 31, 2021, allowing agencies the discretion to continue to provide contractors with relief under Section 3610 of the CARES Act in 2021.

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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:...