1. Home
  2. |Insights
  3. |Pass-Through Cost Proposed Rule

Pass-Through Cost Proposed Rule

Client Alert | less than 1 min read | 07.11.14

The government issued on July 10, 2014, a proposed rule that would require all agencies to justify contract awards, except those to small businesses, that propose to pass through more than 70 percent of the total cost of work to subcontractors by considering the availability of alternative contract vehicles and the feasibility of contracting directly with the proposed subcontractor(s) and to make a written determination that the selected contracting approach is in the best interest of the government. Written comments on the proposed rule are due September 9, 2014.


Insights

Client Alert | 3 min read | 04.14.26

DOJ’s False Claims Act Resolution Against IBM Signals Heightened Risk for Federal Contractors with DEI Programs

On Friday, April 10, 2026, the U.S. Department of Justice (DOJ) announced that International Business Machines Corporation (IBM) has agreed to pay just over $17 million to resolve allegations that it violated the False Claims Act (FCA) by failing to comply with federal anti-discrimination requirements incorporated into its federal contracts due to allegedly discriminatory diversity, equity, and inclusion (DEI) employment practices. This resolution marks the first FCA settlement secured by the DOJ under its Civil Rights Fraud Initiative, created in May 2025, and announced by then-Deputy Attorney General Todd Blanche as part of the administration’s coordinated efforts to target allegedly unlawful DEI practices. Per the agreement, the settlement is neither an admission of liability by IBM nor a concession by the United States that its claims are not well founded....