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Déjà Vu: Congress Orders DCAA to Revise Guidance on Access to Internal Audit Reports

Client Alert | 1 min read | 01.15.13

Section 832 of the FY 2013 NDAA requires DCAA to issue new guidance on access to contractors' internal audit reports to "ensure" that requests for access to them "are appropriately documented," following guidance issued by the agency in August 2012. The revised guidance will require DCAA to keep tabs on such requests and responses to them, but sets limits on what internal audit reports can be used for and stops short of language in the Senate version of the bill, under which the contractor's refusal to provide access would have been "a basis for disapproving the contractor business system or systems."


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Client Alert | 4 min read | 03.05.26

DOL’s Proposed Independent Contractor Rule Reverts to Prioritize Two Core Factors – Likely Limiting Misclassification Claims by Contractors

The U.S. Department of Labor (DOL) has proposed another revision to independent contractor regulations, one that would provide for more leeway in classifying workers as contractors. DOL’s proposed rule, published on February 26, 2026, would rescind the Biden DOL’s March 2024 independent contractor regulation and reinstate a framework substantially tracking the prior Trump rule of January 2021. The proposed rule would also apply the narrower analysis to worker classifications under the Family and Medical Leave Act (FMLA) and the Migrant and Seasonal Agricultural Worker Protection Act (MSPA). The comment period closes in late April 2026; until then, the 2024 rule remains in effect for purposes of private litigation....