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On March 19, 2020 the Office of Management and Budget (“OMB”) issued Memorandum M-20-17, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.”  The memorandum details the administrative relief available to an expanded scope of grant recipients and applicants, both

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On March 20, 2020, the Office of Management and Budget (“OMB”) released guidance to agencies heads on managing federal contract performance issues impacted by COVID-19 [Linked here: M-20-18]. The memo and attached Frequently Asked Questions (“FAQs”) focus on the following main issues:

Telework: agencies are encouraged to maximize telework for contractor employees, wherever

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In its February 18, 2020 Report, the Inspector General for the U.S. Department of Defense (DoD) concluded that $876.8 million in service-disabled veteran-owned small-business (SDVOSB) contracts were improperly awarded due to a lack of verification by contracting officials. The audit, which was conducted to determine whether DoD awarded contracts to businesses that actually qualified

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This week’s episode covers SAM news, OTA news, and proposed rules, and is hosted by partner Peter Eyre. Crowell & Moring’s “Fastest 5 Minutes” is a biweekly podcast that provides a brief summary of significant government contracts legal and regulatory developments that no government contracts lawyer or executive should be without.

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The General Services Administration’s (GSA) System for Award Management (SAM) announced its role in an ongoing Inspector General Investigation into alleged, third party fraudulent activity in SAM.

GSA suspects that the alleged fraudulent activity impacted only a limited number of entities.  GSA has since notified the affected entities, and deactivated their SAM registrations.  GSA also required these entities to validate and confirm their registration and bank account information in SAM before reactivating their SAM registrations.


Continue Reading After Fraudulent Activity in SAM, GSA Implements New Registration Requirements

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The suspension and debarment regulations at Federal Acquisition Regulation (FAR) Subpart 9.4 are focused on the present responsibility of a contractor.  Yet, the records of past, inactive exclusions are available for public view in perpetuity on the System for Award Management website (SAM.gov).   In a recent article (linked here) published in BNA’s Federal Contracts

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On July 29, 2012, the government launched the System for Award Management, known as SAM, which consolidated the Central Contractor Registration (CCR), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS). CCR and ORCA are no longer accepting new or updated submissions, so contractors may be particularly interested in