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Allowability of IR&D Costs: Dis-inflation Run Amok

Client Alert | less than 1 min read | 03.09.11

DOD has issued a proposed amendment to DFARS 231.205-18 (Mar. 2, 2011) that would condition the allowability of independent research and development costs on the reporting of unspecified information about individual projects at least annually and again on completion of projects, using DOD on-line reporting forms. The proposed rule would apply to all contractors with annual IR&D costs in excess of $50,000, an amount that is less than 1% of the threshold in effect in 1990 for reporting IR&D projects under the prior regulatory regime, a mandatory reporting requirement that was completely abolished in 1996.

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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....