GSA Schedule Prices No Longer Presumed Reasonable at DoD
Client Alert | less than 1 min read | 04.07.14
On March 13, 2014, DoD issued a class deviation to FAR 8.404(d) that could make orders under GSA Schedule contracts more burdensome for both contractors and DoD, directing that contracting officers can no longer rely upon GSA's determination of price reasonableness and must instead conduct their own price analysis using the techniques in FAR 15.404-1. When the award is not competitive, those price analysis techniques could include evaluation of prices charged in similar sales or, if it is the only means to determine that the price is reasonable, could even include obtaining cost data to support the pricing of these commercial contracts.
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Client Alert | 4 min read | 06.24.25
CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)
On June 2, 2025, U.S. Customs and Border Protection (“CBP”) issued its first ever Withhold Release Order (“WRO”) and Finding Modifications Guide (“Guide” or “the Guide”). The Guide serves as a roadmap for importers facing a possible WRO or Finding due to allegations of forced labor in the supply chain of their goods imported into the U.S. It provides guidance on information to be included in a modification petition, identifies possible cases in which CBP might request additional information, and provides resources for importers facing a WRO or Finding.
Client Alert | 4 min read | 06.23.25
Selling Electricity to Data Centers or Any End User: Will FERC Regulate You?
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Client Alert | 7 min read | 06.18.25
House Settlement Approved: How to Prepare for Implementation by July 1, 2025
