New Guidance Allows Limited Role for DCAA Audit of Non-DOD Contracts
Client Alert | 1 min read | 02.04.16
The 2016 National Defense Authorization Act prohibits the Defense Contract Audit Agency from providing "audit support" to any non-DOD agency until the Secretary of Defense certifies that DCAA has reduced its backlog of incurred cost audits to 18 months or less, a restriction that could cause some disruption for contractors when DOD contracts are not a majority of the contractor's government work and when audit support has been provided by DCAA in the past. On January 7, 2016, DCAA issued guidance to its auditors that appears to limit the prohibition on "audit support" to incurred cost audits, leaving DCAA auditors free to provide other accounting services to non-DOD agencies, specifically permitting DCAA to perform incurred cost audits that include both DOD and non-DOD contracts when auditors determine that inclusion of the non-DOD contracts involves "de minimis" incremental effort by DCAA, and offering guidance about how to handle such "mixed" audits when the non-DOD contracts will create more than "de minimis" incremental effort.
Contacts
Insights
Client Alert | 4 min read | 12.31.25
Raising the Bar: New York Expands Consumer Protection Law with FAIR Business Practices Act
New York Governor Kathy Hochul has signed into law the most significant update to New York’s consumer protection law in 45 years — the Fostering Affordability and Integrity through Reasonable Business Practices Act, or FAIR Business Practices Act — expanding the scope of the state’s authority to now challenge unfair and abusive business practices. The measure, backed by New York Attorney General (“AG”) Letitia James and signed on December 19, 2025, amends New York’s General Business Law § 349, giving regulators new tools to protect consumers and promote fair marketplace practices.
Client Alert | 4 min read | 12.30.25
Client Alert | 6 min read | 12.30.25
Investor Advisory Committee Recommends SEC Disclosure Guidelines for Artificial Intelligence
Client Alert | 2 min read | 12.29.25
FYI – GAO Finds Key Person “Available” Despite Accepting Employment with a Different Company

