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Interim Rule Eliminates CO Pricing Review of Indirect Offset Costs

Client Alert | less than 1 min read | 06.02.15

Today, DoD issued an interim rule immediately relieving contracting officers (COs) of responsibility for performing a price reasonableness analysis of the costs associated with indirect offsets when mandated by a foreign government customer under a Foreign Military Sales (FMS) contract. The revised rule responds to a "foreseeable trend of increasing numbers and complexity of indirect offsets" on which FMS customers insist and reflects a desire to relieve COs of the burden of performing this analysis when no DoD-appropriated funds are used and when COs have limited ability to evaluate the indirect offset effort in any event.

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Client Alert | 3 min read | 04.24.26

DOL Issues Proposed Rule On “Joint Employment”

On April 21, 2026, the U.S. Department of Labor (DOL) issued a notice of proposed rulemaking (NPRM) outlining a new standard for “joint employment” — under which separate entities will be found jointly liable for the other’s violations — under the Federal Labor Standards Act (FLSA), the Family and Medical Leave Act (FMLA), and the Seasonal Agricultural Worker Protection Act (MPSA). The Proposed Rule purports to standardize the definition of “joint employment” across all three laws to create “clarity” and “uniformity” for employers and employees alike....