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Scope of Proposed Rule on Self-Reporting is Expanded and Would Also Require Self-Reporting of FCA Violations and Contract Overpayments

Client Alert | 1 min read | 05.16.08

The FAR Secretariat today published for public comment an amendment to the proposed rule (73 FR 28407, May 16, 2008) that was previously published at the request of DOJ, to require contractors to have a code of ethics and business conduct and to notify the agency’s Office of Inspector General and the Contracting Officer whenever there is a “reasonable” basis to believe there has been a violation of federal criminal law in connection with a federal contract or subcontract. The amended proposed rule no longer exempts commercial item contracts and contracts that are performed outside the United States and, again at the request of DOJ, adds a requirement that contractors also report violations of the civil False Claims Act as well as contract overpayments, with knowing failures to report such violations being an additional cause for debarment or suspension.

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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....