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 | 09.16.26
CMS Offers Guidance as Scrutiny Rises Over ABA Therapy in Medicaid
Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021.
Client Alert | 4 min read | 09.15.26
GAO Indicates Reasonable Conflict of Interest Investigation Must Include Inquiry of Involved Firm
Client Alert | 3 min read | 09.15.26
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AI in Life Sciences: Ten Legal Considerations and Risks of AI Use in Drug Discovery and Development

