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DCAA Issues Guidance On Revised Travel Cost Rule

Client Alert | 1 min read | 04.12.10

In response to the recent revision to the travel cost rule at FAR 31.205-46(b) and (c), which now limits allowable airfare costs to the lowest airfare available to the contractor, DCAA issued guidance on March 22, 2010, that identifies the "lowest airfare available" as that available to the contractor through direct negotiation with airlines or travel agents. The guidance advises that contractors' policies and procedures should provide for (a) documented, advance planning of travel that considers nonrefundable airfares and lower airfares negotiated with airlines, travel service providers, and credit card companies and (b) obtaining quotations from competing airlines or travel service providers.

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Client Alert | 3 min read | 11.21.25

A Sign of What’s to Come? Court Dismisses FCA Retaliation Complaint Based on Alleged Discriminatory Use of Federal Funding

On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future....

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