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Jay Blindauer Whether a procurement, grant, or cooperative agreement, [1] if the at-issue arrangement qualifies as a contract, the Government cannot simply cease performing contract payments. For a grant or cooperative agreement that is not a contract, the Government has more flexibility to halt payments. 2d 151, 164 (D.
OMB Releases Guidance to Modernize FedRAMP Last week, the Office of Management and Budget (OMB) released updated guidance to modernize the Federal Risk and Authorization Management Program (FedRAMP) and overhaul policies established when the program launched in 2011. Coffey , and Michael E. Authored by Evan C.
Specifically, the GovCon Order applies for contractors/subcontractors of “[e]xecutive departments and agencies, including independent establishments subject to the Federal Property and Administrative Services Act, 40 U.S.C. a personal services contract), it should not be subject to the GovCon Order. [18] Emphasis on the word some.
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