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 | 6 min read | 04.25.24
On April 22, 2024, the Office of Management and Budget (OMB) issued a Final Rule significantly revising the Uniform Guidance for grants, cooperative agreements, and other federal financial assistance. The Final Rule (titled “OMB Guidance for Federal Financial Assistance”), and OMB’s accompanying memorandum to agencies and reference guide, state that the revisions aim to streamline and clarify the grant rules and improve management, transparency, and oversight of federal financial assistance. Agencies must implement the Final Rule by October 1, 2024; however, agencies may apply it to federal awards as early as June 21, 2024.
Client Alert | 3 min read | 04.24.24
Client Alert | 2 min read | 04.24.24
FTC Continues Focus on Tracking Technologies and Personal Health Data
Client Alert | 9 min read | 04.24.24
