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GAO Teaches Course in Cost Realism 101

Client Alert | less than 1 min read | 06.06.07

In Magellan Health Services (Jan. 5, 2007, http://www.gao.gov/decisions/bidpro/298912.pdf), GAO sustained a protest of HHS's award of a cost-plus-fixed-fee contract for employee assistance program services when the agency's cost realism evaluation was unreasonable for several reasons, including a failure to account for insufficient levels of effort and labor rates in the awardee's cost proposal. After chiding the agency for not adjusting the awardee's cost proposal in accordance with the recommendations of the agency's own cost analyst, GAO found the adjusted costs were still lower than the protestor's but the smaller delta required the agency to take another look at its unsupported conclusion that the offerors were "technically equal."

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Client Alert | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

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)....