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Strict Application Of Micro-Purchase Exception Sinks Award

Client Alert | less than 1 min read | 04.15.10

In Rapiscan Sys., Inc. (Mar. 15, 2009), a case handled by C&M, GAO sustained a protest of the award of a purchase order under a Federal Supply Schedule ("FSS") solicitation when the awardee's FSS contract did not include one of the solicitation's required line items. Although the awardee priced the non-FSS item at $0, GAO concluded that the micro-purchase exception did not apply, because the vendor's quotation also stated that the non-FSS item's price (which exceeded the $3,000 micro-purchase threshold) was included in the price of an FSS item.

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Client Alert | 14 min read | 03.13.26

AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems

On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities.  The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards.  The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed.  GSA requests comments by March 20, 2026....