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The Confusing World of Compensation Caps

Client Alert | less than 1 min read | 01.13.14

As a result of the confusing, inconsistent, and in some cases unenforceable changes made in the cost allowability rules setting caps on compensation costs in recent months, it is difficult to determine what rules apply to some contracts. We prepared the attached chart, which we hope will be useful, summarizing our understanding of the various sets of regulatory and statutory provisions that are likely to be applicable to currently active contracts as a tool for deciding how many alternative indirect cost submissions could be required.


Insights

Client Alert | 3 min read | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...