Proposed DFARS Rule to Provide Guidance on Assessing Commercial Price Reasonableness
Client Alert | less than 1 min read | 08.05.15
On August 3, the DoD issued a proposed rule, with comments due by October 2, to amend the DFARS to clarify the amount and types of data that contracting officers may require from contractors in order to perform price reasonableness assessments for commercial items. The proposed rule addresses (1) the conditions under which prior sales information is sufficient, (2) when "uncertified cost data" will be required and the required format, and (3) the limits on requiring additional cost information when there are "sufficient nongovernment sales to establish reasonableness of price."
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Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements. Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.
Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine
Client Alert | 2 min read | 07.13.26
Department of War Immediately Suspends CMMC Phase II Requirements, Launches 60-Day Reform Review
Client Alert | 3 min read | 07.10.26
