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New Rule Prescribes Data Required for Adequate Final Indirect Cost Rate Proposal

Client Alert | 1 min read | 06.02.11

On May 31, 2011, the FAR Council published a final rule governing contract closeout requirements, including the identification of a long list of data items required for a final indirect cost rate proposal to be found "adequate," as well as additional types of data that the government can request to supplement a proposal; clarification of the division of duties between the CO and auditors with respect to auditing and finalizing the proposal; and the requirement that mandatory withholdings be exacted by the CO for contractors who fail to timely submit an adequate proposal. While the rule does not require that proposals be submitted using any particular format in order to qualify as "adequate," it remains unclear what will happen in individual cases if DCAA refuses to commence an audit because the contractor declines to provide the burdensome cost schedules required by the DCAA "model" format.

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Client Alert | 10 min read | 09.24.24

ESG Opponents' Antitrust Accusations: Do They Make Sustainability Collaboration Dangerous?

Investors pursuing environmental, social, and governance (ESG) programs or applying sustainability standards have recently faced high-profile antitrust accusations, leading some to reconsider their participation in certain sustainable investment groups. On August 9, 2024, Climate Action 100+ confirmed the withdrawal of a major investor from the initiative, less than two weeks after the Judiciary Committee of the U.S. House of Representatives had sent information requests to more than 130 of the group’s members as part of an investigation into ESG programs. This follows numerous similar requests by the Committee since December 2022, as well as similar requests and threats of legal action against asset managers by some State Attorneys General since August 2022....