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VA Consolidates Fraud Detection, Prevention, and Enforcement Efforts

Client Alert | 1 min read | 06.08.17

Continuing the Trump Administration’s focus on fraud, waste, and abuse, Veterans Affairs Secretary Dr. David Shulkin announced a program to consolidate fraud detection, prevention, and remediation efforts in VA administered programs. The program, called Seek to Prevent Fraud, Waste, and Abuse (STOP FWA), consolidates fraud prevention and remediation efforts within VA health, benefits, and cemeteries programs and is expected to partner with other federal agencies to leverage best practice in fraud prevention, detection, and enforcement. Information sharing among fraud detection and remediation programs has accelerated in recent years across the government, and contractors are well served to consider a holistic approach to investigating (and, if needed, disclosing) misconduct because it is increasingly likely that multiple government stakeholders will be interested in the outcome.

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:...