The Office of Management and Budget Memorandum M-12-16, dated July 11, 2012, required agencies to accelerate payments to prime contractors so they could, in turn, accelerate payments to their small business subcontractors. Our previous blog on that OMB memorandum is located here. As a result DoD has been including a new clause 52.232-99 “Providing Accelerated Payment to Small Business Subcontractors” in their contracts.
The clause requires prime contracts that receive accelerated payments to similarly accelerate their payments to small business subcontractors. The clause was drafted pursuant to class deviation 2012-O0014 but the FAR council has opened FAR Case 2012-031 to draft more generally applicable FAR clause covering this subject. At this point, any small business subcontractors should ask their prime contractors about making accelerated payments if they are not doing so already.
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What We Are Writing
- A Marriage of Inconvenience: GSA Schedule Contracts & The Contractor Code of Business Ethics & Conduct Clause
- Emerging Small Businesses: To Grow Your Business, You Must Plan For Growth
- Government Contracting: Look Before You Leap!
- GSA Schedules – Strategies for Success
- New Employee vs. Independent Contractor Considerations
- Pay on Display – Understanding the Executive Compensation and Subcontractor Data Reporting Requirements & Ramifications
- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)