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Treasury Issues Guidance on the Coronavirus State and Local Fiscal Recovery Funds under the American Rescue Plan Act

Client Alert | 1 min read | 05.17.21

On May 17, 2021, the U.S. Department of the Treasury officially published an Interim Final Rule to provide long-awaited guidance on the Coronavirus State Fiscal Recovery Fund and the Coronavirus Local Fiscal Recovery Fund (“the Fiscal Recovery Funds”) established under the American Rescue Plan Act (“ARPA”).  To facilitate the disbursement of these funds, this Interim Final Rule establishes a framework for determining the types of programs and services that are eligible under the ARPA along with a list of eligible uses that State, local, and Tribal governments may consider.  While State, local, and Tribal governments have the flexibility to determine how best to use the Fiscal Recovery Funds to meet the needs of their communities and populations, this funding, along with its recipients and subrecipients, will be subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 C.F.R. Part 200.

To learn more about this Interim Final Rule and better understand the opportunities and risks for companies, please read our blog post here.

Insights

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....