IR&D Reporting Requirements Reinstated
Client Alert | 1 min read | 01.30.12
In a final rule published today, the DFARS were amended to reinstate a requirement that was eliminated from the regulations in the early 1990s, providing that as a condition of allowability for Independent Research and Development (IR&D) costs, major contractors must submit to DoD at least annually technical descriptions of the IR&D projects that the contractor claims as allowable. In response to criticism of a draft regulation proposing a $50,000 coverage threshold, the final rule limits mandatory reporting to “major contractors” that allocate more than $11 million annually to “covered contracts” (a term that excludes fixed-price contracts without cost incentives), leaves largely to the contractor’s discretion how much detail needs to be reported in the on-line template through which the reports must be submitted, encourages voluntary reporting by contractors not subject to the mandatory requirement, and promises that the reports will be exempt from disclosure under the Freedom of Information Act.
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Client Alert | 4 min read | 04.14.26
FedRAMP Solicits Public Comment on Overhaul to Incident Communications Procedures
The Federal Risk and Authorization Management Program (FedRAMP) continues to advance its modernization agenda. On April 8, 2026, FedRAMP released RFC-0031, Updated Incident Communications Procedures for public comment. This RFC proposes replacing the current FedRAMP Incident Communications Procedures (ICP) with what FedRAMP calls “a clear set of reporting requirements … established using a modern rules-based format.”
Client Alert | 5 min read | 04.14.26
Client Alert | 4 min read | 04.14.26
Client Alert | 5 min read | 04.13.26
EU Pharma Package: Global (Orphan) Marketing Authorization Compromise Proposal

