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OMB's Newly Proposed Acquisition Pilot Program Could Be a Game-Changer

Client Alert | 1 min read | 06.13.19

In late April, the Office of Management and Budget (OMB) sent a letter to Congress, which contained a number of legislative proposals to streamline and improve the agility and efficiency of the federal acquisition process, one of which would establish an “Acquisition Modernization Test Board.” According to the letter, this Board would authorize the Administrator of the Office of Federal Procurement Policy (OFPP) “to exercise a waiver of one or more acquisition or procurement laws as part of a pilot program to evaluate how changing the statutory requirement(s) might facilitate more efficient achievement of the purpose underlying the law.” Importantly, this proposal would give OFPP enormous discretion and flexibility to pilot innovative and new approaches to streamlining and deregulating acquisitions. OMB seeks enactment of this and other proposals as part of Title 8 (the acquisition title) of the Fiscal Year 2020 National Defense Authorization Act, and, assuming that Congress approves this expanded authority for OFPP (either as part of an NDAA or otherwise), industry should take this opportunity to recommend innovative acquisition pilots. 

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Client Alert | 2 min read | 10.17.24

FTC’s New “Click to Cancel” and What It Means for Businesses with Any Form of Subscription, Membership, or Auto-Renew or Recurring Payment Program

On October 16, 2024, over 18 months after first issuing its proposed rule, the Federal Trade Commission (“FTC”) issued a final rule to make it easier for consumers to cancel their subscriptions, memberships, automatic renewals, and other recurring payment options.  This rule reaches consumers and businesses in all sorts of industries: from gym memberships to e-commerce and delivery app subscriptions, internet services, cable, cell phone, and broadband and streaming services, gift box services, and even spa memberships, the examples abound. The purpose behind the rule is to increase transparency and make it easier for consumers to cancel subscriptions, saving them time and money by ending the “doom loop” some may find themselves in when trying to cancel such a feature....