LOC Clause Applies To Each Delivery Order, Not Full Contract
Client Alert | 1 min read | 07.30.04
In Analysas Corp. (May 12, 2004), the ASBCA held that, under an indefinite quantity cost-plus-fixed-fee contract for services, the contract’s limitation of cost (“LOC”) clause (which required the contractor to give notice if its costs were expected to exceed 75% of the "estimated cost specified in the Schedule") allowed the government to deny payments to a contractor for costs it incurred in excess of the estimated cost for each delivery order, even though the contractor had not yet exceeded 75% of the maximum total labor hours specified "in the Schedule" for the full contract. The Board reasoned that the contract lacked the “critical provision” of a specific dollar figure "in the Schedule" for the total estimated contract cost, instead allowing for later addition of estimated costs for each delivery order that the government issued.
Contacts
Insights
Client Alert | 5 min read | 09.02.26
DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement
On Tuesday, August 25, 2026, the U.S. Department of Justice (DOJ) announced that Deloitte LLP and several of its subsidiaries agreed to pay, collectively, $21.5 million to resolve allegations that Deloitte violated the False Claims Act (FCA) by failing to comply with new anti-discrimination requirements incorporated into its federal contracts, by discriminating against employees and applicants on the basis of race and sex, and by allocating and seeking reimbursement for costs related to those practices under its federal government contracts. This resolution is the second of its kind under DOJ’s recently launched Civil Rights Fraud Initiative, following a similar settlement by IBM in April 2026.
Client Alert | 4 min read | 09.02.26
Client Alert | 7 min read | 09.02.26
OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks
Client Alert | 4 min read | 09.02.26
The CSC Is Investigating: What Its New NIL Enforcement Memo Means for Institutions

