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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 This deviation is “effective until it is incorporated in the DFARS” or otherwise rescinded.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 | 5 min read | 04.01.26

OPO Hospital Waiver Litigation: Trends and Takeaways

Despite facing existential challenges in several federal courts, the performance metrics established by the Centers for Medicare and Medicaid Services’ (CMS) 2020 Final Rule for organ procurement organizations (OPO) appear to be, at least for now, withstanding scrutiny in litigation proceedings.  ...