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Contracts Mean What They Say: Contractor Entitled to Invoice for Total Hours Worked under Labor Hours Contracts

Client Alert | 1 min read | 07.30.12

In GaN Corp. (July 13, 2012), the government argued that the Payments Under Time-and-Materials and Labor-Hour Contracts clause permitted the contractor to bill on the labor-hour task orders at issue only those hours for which salaried exempt employees had been "paid" by the contractor, not for so-called "uncompensated overtime" hours worked by those salaried employees. It is not clear from the decision how the government proposed to determine the number of hours for which the salaried employees were not "paid," but what is clear is that the Board rejected the argument and held that under the plain meaning of the clause the contractor was entitled to invoice for the total number of hours actually worked by each employee at the hourly rate specified in the contract for that employee, regardless of the amount paid to the employee.

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Client Alert | 2 min read | 12.19.25

GAO Cautions Agencies—Over-Redact at Your Own Peril

Bid protest practitioners in recent years have witnessed agencies’ increasing efforts to limit the production of documents and information in response to Government Accountability Office (GAO) bid protests—often will little pushback from GAO. This practice has underscored the notable difference in the scope of bid protest records before GAO versus the Court of Federal Claims. However, in Tiger Natural Gas, Inc., B-423744, Dec. 10, 2025, 2025 CPD ¶ __, GAO made clear that there are limits to the scope of redactions, and GAO will sustain a protest where there is insufficient evidence that the agency’s actions were reasonable....