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The Top FCA Developments Of 2018

Client Alert | 1 min read | 02.04.19

From the government’s renewed use of its dismissal authority to changes to the policy on corporate cooperation credit, the second year of False Claims Act (FCA) enforcement under the Trump administration was defined by several announcements concerning how the Department of Justice (DOJ) will pursue cases under the FCA. These policy reforms are among the many FCA developments highlighted by C&M attorneys in a "Feature Comment" published in The Government Contractor, which considers key issues such as small business fraud, materiality post-Escobar, trade and domestic preferences, and the Supreme Court’s review of a circuit split concerning the statute of limitations.

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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:...