Executive Compensation Limits Expanded
Client Alert | 1 min read | 01.05.12
Section 803 of the National Defense Authorization Act of 2012, signed by the President on December 31, 2011, expands the existing limit on "senior executive" compensation to cover all employees and purports to apply the new allowability limitation effective January 1, 2012, to existing contracts, although "the Secretary of Defense may establish one or more narrowly targeted exceptions for scientists and engineers upon a determination that such exceptions are needed to ensure that the Department of Defense has continued access to needed skills and capabilities." The most recent cap published by the Office of Federal Procurement Policy was $693,951 for 2010 (no cap was published in 2011, apparently for political reasons), so as a practical matter the expansion of the cap to all employees is likely to have limited impact, but the provision purporting to apply the new limit to existing contracts is almost certainly unenforceable.
Insights
Client Alert | 5 min read | 06.05.26
The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332).
Client Alert | 5 min read | 06.04.26
EU Pay Transparency Directive: The Transposition Deadline is Looming — What Now?
Client Alert | 4 min read | 06.04.26
Surveillance Pricing Update: California’s Sweeping AB 2564 Passes Assembly and Heads to Senate
Client Alert | 4 min read | 06.04.26
USTR Proposes Sweeping Tariffs as Part of Section 301 Forced Labor Import Enforcement Investigation
