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  3. |Double Take: The DoD OIG Recommends Attempting to Recoup $43 Million in Purportedly Expressly Unallowable Costs Not Previously Disallowed

Double Take: The DoD OIG Recommends Attempting to Recoup $43 Million in Purportedly Expressly Unallowable Costs Not Previously Disallowed

Client Alert | 1 min read | 02.13.20

On January 14, 2020, the Department of Defense (DoD) Office of Inspector General (OIG) released a report examining whether Defense Contract Management Agency (DCMA) contracting officer (CO) rejections of recommendations by the Defense Contract Audit Agency (DCAA) to assess penalties on $43 million in unallowable costs identified in 18 DCAA audit reports complied with the Federal Acquisition Regulation (FAR), DoD Instructions, and agency policy. The OIG did not take issue with the fact of the COs’ disagreements, nor did it take a position on the merits of the COs’ determinations. But the OIG did conclude that the COs did not adequately document their reasons for rejecting DCAA’s penalty recommendations. Accordingly, the OIG recommended that DCMA reevaluate the COs’ decisions not to assess penalties on the $43 million, take actions to reclaim any expressly unallowable costs not previously disallowed, and collect from the contractors any penalties due to the Government. DCMA stated that it would review the audit reports and attempt to recoup costs and/or penalties and interest that DCMA COs previously decided not to pursue, as appropriate.

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Client Alert | 8 min read | 12.11.25

Director Squires Revamps the Workings of the U.S. Patent Office

In March 2025, President Trump nominated John A. Squires for the positions of Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office (USPTO). After being approved by the Senate Judiciary Committee by a vote of 20-2, Squires was confirmed by the Senate on September 17, 2025, by a vote of 51-47 after anti-filibuster measures were invoked. During and after the confirmation process, Squires emphasized several goals for the USPTO during his time as Director. Such goals included:...