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 | 3 min read | 02.26.26
FERC Requires Refunds for Late QF Recertification
On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners.
Client Alert | 6 min read | 02.24.26
Artificial Intelligence and Human Resources in the EU: a 2026 Legal Overview
Client Alert | 3 min read | 02.24.26
DOJ v. OhioHealth Confirms Antitrust Enforcers’ Continued Focus on Health Care Markets
Client Alert | 4 min read | 02.24.26

