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OMB Seeks to Jettison Defense CAS Board and De-Couple CAS and TINA

Client Alert | 1 min read | 06.07.19

In late April, the Office of Management and Budget (OMB) sent a letter to Congress containing a number of legislative proposals to streamline and improve the federal acquisition process for inclusion in the Fiscal Year (FY) 2020 National Defense Authorization Act (NDAA). Two of those proposals relate to the Cost Accounting Standards (CAS). The first calls for the disestablishment of the Defense CAS Board—which was a product of the FY 2017 NDAA—to avoid creating a more complicated CAS regulatory framework. The second would de-link the monetary threshold for CAS from the Truthful Cost or Pricing Data threshold (formerly known as TINA), and increase the basic threshold for CAS applicability from $2 million to $15 million. These are two recommendations that the Section 809 Panel made in Volume II of its Report (the CAS Board is also considering repeal of the provisions establishing the Defense CAS Board and increasing the CAS applicability thresholds).

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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....