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DCAA Executive Compensation Calculation Rejected (Again)

Client Alert | less than 1 min read | 06.21.12

In Metron, Inc., decided on June 4 by the ASBCA, DCAA's flawed methodology for assessing the reasonableness of executive compensation paid by government contractors was rejected for the second time this year by the Board. The board found that Metron appropriately based its compensation decisions on data in a single survey that was most relevant to Metron's business, found that other survey data that DCAA relied on was not relevant to Metron's compensation costs, and rejected all of the "adjustments" that DCAA had made to the relevant survey data because the adjustments were based on speculation and assumptions that were not supported by factual evidence.


Insights

Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs....