The End is Near: DCAA Projects End of Incurred Cost Backlog by FY 2018
Client Alert | 1 min read | 06.11.18
The Defense Contract Audit Agency (DCAA) recently made public its Fiscal Year 2017 Report to Congress, which, among other things, provides an update on incurred cost audits. According to DCAA, it is “on track to eliminate the backlog by the close of FY 2018” as it now has “under 3,000 incurred cost years in [such] backlog….” However, it is important to remember that DCAA does not consider an audit backlogged unless it is “older than two fiscal years.”
The report also covers other aspects of incurred cost audits (e.g., sustained audit exceptions), which are discussed more fully in our blog post on the topic.
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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 (Level I and II self assessments are still permitted). 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 | 07.15.26
Client Alert | 3 min read | 07.14.26
Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine
