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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 | 5 min read | 09.03.26

DOT Final Rule Narrows Airline Delay and Cancellation Reporting Obligation Under FAA Reauthorization Act of 2024

The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events....