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Raise Confirmed! DoD Finalizes Doubling of CPSR Threshold

Client Alert | 1 min read | 01.10.20

Effective December 31, 2019, the DoD issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a DoD contractor purchasing system review (CPSR) threshold of $50M at DFARS 244.302, doubling the existing $25M threshold at FAR 44.302(a). The final rule adopts the proposed rule (discussed here) without any substantive changes. In response to a comment, the final rule clarifies that contractors whose relevant sales have not reached the new threshold may opt to allow their approval to expire rather than incur the costs to maintain a system that meets the criteria for an approved system; in that case, the Government and contractor would continue with consent packages. But, if an approved purchasing system is necessary to support a particular program, the contractor can work with the contracting officer to obtain a CPSR based on risk or pressing need. The final rule also notes that it is a simple increase in the threshold, and does not impact any existing provisions or clauses.

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Client Alert | 3 min read | 05.13.25

DOL Issues Revised Independent Contractor Misclassification Guidance

The classification of “independent contractors versus employees” – a political football that has undergone many iterations as the White House switched between political parties – has again changed hands. The U.S. Department of Labor (“DOL”) has now introduced new guidance, consistent with earlier Republican iterations, while rejecting the 2024 Democratic formulation. It remains to be seen whether the courts will give DOL much deference in this area....