DFARS Excessive Pass-Through Cost Rule Modified
Client Alert | 1 min read | 05.13.08
Effective May 13, 2008 (73 Fed. Reg. 27464), the widely-criticized interim DFARS rules about "excessive pass-through costs" published last April were modified in yet another interim rule to address the confusion created by the interim rules. The most important features of the new interim rules are in the prefatory comments, which emphasize repeatedly that the requirement for reporting when subcontract effort will exceed 70 percent applies both before and after award, but is only a reporting requirement, not a threshold for coverage, and that the rules do not apply to any contract, no matter what the subcontract content, where the contractor demonstrates "added value," a term that is defined in the interim regulations to include performance of "subcontract management functions that the Contracting Officer determines are a benefit to the Government (e.g., processing orders of parts or services, maintaining inventory, reducing delivery lead times, managing multiple sources for contract requirements, coordinating deliveries, performing quality assurance functions)."
Insights
Client Alert | 3 min read | 06.30.26
Qatar Labor Law: Key Amendments Introduced by Law No. 9 of 2026
Qatar has enacted Law No. 9 of 2026, amending the Labour Law issued by Law No. 14 of 2004. The amendments cover the scope of the application of the Labour Law, vocational certification, noncompete clauses, the right to strike, joint committees, dismissal grounds, and enforcement powers. Employers should review their employment practices and documentation to ensure compliance.
Client Alert | 2 min read | 06.29.26
When Trade Secret Theft Becomes Racketeering: What the Fifth Circuit’s New Ruling Means
Client Alert | 7 min read | 06.26.26
Federal Roundup: Updates for PBMs and Medicare Advantage Organizations
Client Alert | 6 min read | 06.26.26
