DCAA's Use of a Statistically Invalid Analysis for Testing Compensation Reasonableness
Client Alert | less than 1 min read | 02.03.12
The ASBCA in J.F. Taylor, Inc. (Jan. 18, 2012) rejected DCAA’s disallowance of executive compensation, based primarily on the credibility of differing expert opinions. The board concluded that the standard DCAA analysis relying on a “rule of reason” that permits compensation within 10% of the 50th percentile of an unweighted average of multiple surveys with different sample sizes is statistically invalid, at least in part because the contractor’s expert was credible and the government’s, who had included in his resume what was arguably a mail order PhD from a South African “university,” was not.
Insights
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies.
Client Alert | 8 min read | 04.27.26
Client Alert | 5 min read | 04.27.26
Drift Protocol Exploit: Why “Social Trust” Is the Newest Cybersecurity Gap
Client Alert | 4 min read | 04.27.26
Gaming Addiction Litigation: Turner v. Epic Games & Roblox and What It Means for the Industry
