Separate CAS Noncompliances May Get Separate SOL
Client Alert | 1 min read | 01.22.14
In Appeal of Fluor Corp., the ASBCA held that the government's claim relating to an alleged CAS 403 noncompliance "was a continuing claim inherently susceptible to being broken down into a series of independent distinct events," namely, each payment by the government for a CAS-non-compliant billing. Thus, the board held that, under the CDA's statute of limitations, the government "knew or should have known" that it had a claim against the contractor as of the date the compliance audit was completed (for amounts paid before that date), but that claims for the same alleged CAS noncompliance in subsequent years would not accrue until the amounts at issue for those years had been billed and paid, a result that may save some government claims from the CDA's 6-year SOL (previously discussed here, here, here, here, and here).
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Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26

