Today, August 13, the Office of Management and Budget (OMB) published a series of changes to the OMB Guidance for Grants and Agreements, including the addition of 2 CFR 200.216, Prohibition on certain telecommunication and video surveillance services or equipment, which prohibits grant and loan recipients and subrecipients from using federal funds to
GSA Panel to Discuss New Section 889 Interim Rule Implementation
Last week, the General Services Administration (GSA) announced that the Office of Governmentwide Policy would hold a live and recorded virtual webinar panel on August 12, 2020 to discuss the new interim rule implementing the 2019 National Defense Authorization Act Section 889(a)(1)(B) covered telecommunications prohibition.
The panel is expected to address the implementation and application
FAR Council Publishes 2019 NDAA Section 889(a)(1)(B) Interim Rule Further Prohibiting Use of Huawei, ZTE, and Others’ Telecommunications Technology by Contractors
On July 14, the FAR Council published an interim rule revising FAR 52.204-24 and FAR 52.204-25 to implement Section 889(a)(1)(B) of the 2019 National Defense Authorization Act (NDAA) prohibiting executive agencies from entering into, renewing, or extending contracts with contractors that use Huawei, ZTE, or other identified telecommunications equipment and services (“covered telecommunications equipment and
PRAC Report Confirms OIG Focus on Combatting Fraud Related to Emergency Funding Programs
On June 17, 2020, the Pandemic Response Accountability Committee (PRAC) issued its first report, “Top Challenges Facing Federal Agencies: COVID-19 Emergency Relief and Response Effort” (the “Report”). PRAC was established by the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). It consists of the twenty-one offices of inspectors general (OIGs) that oversee the
Coronavirus Update: First Pandemic Response Accountability Committee Report Emphasizes Government-Wide Concerns About Fraud and Grant Management
On Wednesday, June 17, 2020, the Pandemic Response Accountability Committee (“PRAC”), composed of 21 Offices of Inspector General overseeing agencies that received the most CARES Act funds, released its first report, “Top Challenges Facing Federal Agencies: COVID-19 Emergency Relief and Response Efforts.” The report was derived from information provided by 37 Offices of Inspector
Revisions to DOJ’s Corporate Compliance Guidance Indicate that a Dynamic, Data-Driven and Well-Resourced Compliance Program is More Important than Ever
On Monday, June 1, 2020, the Department of Justice’s (DOJ’s) Criminal Division issued an updated version of the “Evaluation of Corporate Compliance Programs” guidance. The guidance was originally published by the Criminal Division’s Fraud Section in February 2017, and last revised in April 2019. The updated guidance emphasizes the need for companies to
Coronavirus Update: GSA Issues Class Deviation Regarding Implementation of Section 3610 of the CARES Act
On April 21, 2020, the General Services Administration (GSA) Office of Governmentwide Policy, issued Class Deviation CD-2020-12, effective immediately, which sets forth implementation guidance for Section 3610 of the CARES Act and creates a new General Services Administration Acquisition Regulation (GSAR) contract clause.
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Coronavirus Update: GSA Makes BAA and TAA Non-Availability Exception Due to COVID-19 National Emergency, Applicable to GSA Schedule Orders
On April 3, 2020, the General Services Administration (GSA) issued a class determination of non-availability under both the Buy American Act (BAA) and Trade Agreements Act (TAA) clauses, effective through July 1, 2020 and applicable to GSA Schedule orders, to address the immediate and urgent needs of GSA and other agencies to preserve lives in
Launch of GSA Coronavirus Procurement-Related Website
The General Services Administration (GSA) recently launched a website dedicated to Coronavirus Acquisition-Related Information and Resources. It’s our understanding that the website will be updated regularly and will create a helpful catalogue of public facing guidance, policies, frequently asked questions, and other information generated by federal government agencies on COVID-19-related procurement matters. In addition, the
OMB Issues Additional Guidance to Grant Recipients
As signaled as a possibility in its March 9, 2020 guidance in Memorandum M-20-11, the Office of Management and Budget (OMB) issued Memorandum M-20-17 on March 19 to provide short term administrative, financial management and audit relief from the 2 CFR Part 200 Uniform Guidance requirements to a broader scope of recipients of grants