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Crowell & Moring – 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. Although GSA does not expect to use Section 3610 broadly to reimburse GSA contractors for paid leave, the class deviation recognizes that it is important for GSA to “establish clear direction” for assisted acquisitions and for contracts GSA establishes for other agencies to use.

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