DoD Issues Class Deviation For Small Business Joint Venture Offerors Until SAM Is Updated to Account for Recent FAR Revisions
Client Alert | 1 min read | 10.27.22
On October 26, 2022, the Department of Defense published a class deviation establishing alternative procedures for verifying the small business size and status of joint venture offerors. This class deviation is necessary because, effective October 28, 2022, the Federal Acquisition Regulation has been updated to include new certifications for use by joint venture offerors in FAR solicitation provisions 52.212-3 and 52.219-1—via a FAR update on which Crowell previously reported. Due to a lag in system implementation in the System for Award Management (SAM) and in the interface between SAM and the Small Business Administration, SAM will not reflect the new representations immediately. As such, DoD’s class deviation provides language for contracting officers to use in solicitations in lieu of relying on SAM for size and status certifications of joint venture offerors.
Insights
Client Alert | 1 min read | 01.10.25
FAR Council Withdraws Proposed Mandatory Climate Disclosures for Federal Contractor Rule
Mandatory climate disclosures for US federal contractors are officially off the table—at least, for the foreseeable future. On January 10, 2025, the Department of Defense, General Services Administration, and National Aeronautics and Space Administration announced that they are withdrawing a proposed rule, “Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk,” which would have required thousands of federal contractors to inventory and publicly disclose their Scope 1 and Scope 2 greenhouse gas (GHG) emissions and would also have required “major” contractors to also establish and validate GHG emission-reduction targets tailored to the goals of the Paris Agreement. The proposed rule, discussed in further detail here, was introduced in November 2022 and resulted in thousands of public comments from the government contractor community and beyond.
Client Alert | 7 min read | 01.10.25
New Draft Guidance From FDA Explains When an Accelerated Approval Trial Is “Underway”
Client Alert | 11 min read | 01.10.25
Client Alert | 7 min read | 01.09.25
Navigating Disputes on Megaprojects Amid Trump Tariffs - Part 2
