DFARS Deviation Removes “Technical Interchange” Requirement for IR&D Cost Allowability
Client Alert | 1 min read | 09.25.17
On September 14, 2017, the Department of Defense issued a Class Deviation waiving the requirement for “major contractors” to “engage in” and “document” a “technical interchange” with DoD as a prerequisite to making costs for IR&D projects allowable (previously discussed here and here). This deviation is “effective until it is incorporated in the DFARS” or otherwise rescinded. While it is certainly good news for contractors, it does not impact the portion of the rule requiring contractors to report at least annually IR&D projects to DTIC as a condition of allowability
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Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
