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State of Suspension and Debarment

Client Alert | less than 1 min read | 08.10.18

The Interagency Suspension and Debarment Committee recently issued its report on FY2017 exclusion statistics. The report highlighted a substantial decline in numbers of exclusions (approximately 14 percent) and an increase in numbers of proactive contractor outreach efforts to SDOs. While the decline in overall governmentwide exclusion activity does not directly correlate with increased proactive contractor engagement, the overarching message from this report is the value of contractor outreach to suspending and debarring officials to avoid being excluded from government contracting and federal assistance programs.

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:...