Failure to Consider CAS Materiality Criteria Dooms Gov’t Claim
Client Alert | 1 min read | 11.10.16
In Raytheon Co. (ASBCA Aug. 9, 2016), a case involving disallowed cost increases following voluntary accounting changes, the board ruled that the CO violated FAR 30.602 and abused her discretion by considering only the amount of the dollar impact of the accounting changes and, thus, “fail[ed] to analyze the materiality of the cost impacts at issue” pursuant to the criteria set out in CAS 9903.305. Noting (without deciding) that a cost impact of less than 0.005 percent across affected contracts (roughly $142 per contract) might not be “material,” the board held that the government cannot recover on its claim when the CO “simply disregard[s],” rather than evaluates, the CAS materiality factors.
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Client Alert | 5 min read | 12.23.25
An ITAR-ly Critical Reminder of Cybersecurity Requirements: DOJ Settles with Swiss Automation, Inc.
Earlier this month, the Department of Justice (DOJ) announced that Swiss Automation Inc., an Illinois-based precision machining company, agreed to pay $421,234 to resolve allegations that it violated the False Claims Act (FCA) by inadequately protecting technical drawings for parts delivered to Department of Defense (DoD) prime contractors. This settlement reflects DOJ's persistent emphasis on cybersecurity compliance across all levels of the defense industrial base, reaching beyond prime contractors to encompass subcontractors and smaller suppliers. The settlement is also a reminder to all contractors not to overlook the often confusing relationship between Controlled Unclassified Information (CUI) and export-controlled information.
Client Alert | 2 min read | 12.23.25
Record-Setting False Claims Act Settlement Highlights DOJ Commitment to Customs Enforcement
Client Alert | 22 min read | 12.23.25
Client Alert | 6 min read | 12.22.25
Emerging Legal Issues for Skilled Nursing Facilities in New York: A Year in Review
