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Sequestration: The Prequel

Client Alert | 1 min read | 09.26.12

On July 31, 2012, the Defense Procurement and Acquisition Policy (DPAP) office issued a "class deviation" to implement the provisions of section 808 of the 2011 National Defense Authorization Act which prohibit DOD from spending more on contracts for services in 2012 and 2013 than it spent in 2010. The "deviation" requires that CO's set negotiation objectives that do not exceed the labor rates and overhead rates that were in effect during 2010 for the same services, but because the "deviation" also requires that award of any contract that was priced based on rates in excess of those negotiation objectives must be approved by the secretary of the relevant military department or the head of the contracting activity, many DOD CO's are treating the "deviation" as a cap on allowable labor and overhead rates, regardless of any justification that may exist for rate increases.


Insights

Client Alert | 5 min read | 09.02.26

DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement

On Tuesday, August 25, 2026, the U.S. Department of Justice (DOJ) announced that Deloitte LLP and several of its subsidiaries agreed to pay, collectively, $21.5 million to resolve allegations that Deloitte violated the False Claims Act (FCA) by failing to comply with new anti-discrimination requirements incorporated into its federal contracts, by discriminating against employees and applicants on the basis of race and sex, and by allocating and seeking reimbursement for costs related to those practices under its federal government contracts. This resolution is the second of its kind under DOJ’s recently launched Civil Rights Fraud Initiative, following a similar settlement by IBM in April 2026....