OMB and DoD Do Sequestration Two-Step
Client Alert | less than 1 min read | 08.13.12
On August 1, 2012, Acting OMB Director Jeffrey Zients and Deputy Secretary of Defense Ashton Carter testified before the House Armed Services Committee regarding the potential impacts of sequestration set to begin on January 2, but declined to spell out whether OMB would apply sequestration at the program, project, or activity level – the key to determining whether agencies would have some discretion to pick and choose among contracts. Sec. Carter hinted that DoD would follow that approach, stating that the DoD leadership "will take advantage of any flexibility [they] can find" to reach the target cuts, although any such flexibility is already restricted by the Administration's announcement that payroll accounts for military personnel would be exempt.
Contacts
Insights
Client Alert | 5 min read | 09.03.26
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.
Client Alert | 6 min read | 09.03.26
FDA Seeks Input for Regulating GenAI-Powered Medical Devices
Client Alert | less than 1 min read | 09.03.26
SBA Proposal to Overhaul Size Standards Would Transform Federal Government Contracting
Client Alert | 5 min read | 09.02.26
DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement

