‘Tis the Season: Contracting Officer’s Final Decisions on 2011 Incurred Costs
Client Alert | 1 min read | 07.02.18
For contractors that use a fiscal year that ends on 12/31 and submitted their 2011 incurred cost submissions to the Government in June of 2012, the 6-year deadline for the Government to assert a claim disallowing a portion of those costs is upon us. As a practical matter, DCAA’s well-documented audit backlog means that some COs are likely to receive audit reports only weeks before the deadline (or not at all), and may be inclined to issue COFDs disallowing all of the costs identified in DCAA’s audit reports, in order to preserve the Government’s right to pursue a claim. Contractors should be mindful of the 90-day limit to appeal a Final Decision even where they expect to negotiate a resolution with the Government.
Contacts
Insights
Client Alert | 4 min read | 08.27.26
FCC Clarifies Covered List for Power Inverters and Advanced Robotic Devices
On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List — established through the Secure and Trusted Communications Networks Act — to include foreign-produced connected power inverters and advanced robotic devices, following an executive branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.” Equipment on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products without an exception or approval.
Client Alert | 4 min read | 08.27.26
Power Play: New Executive Order Targets Electrical Grid Equipment
Client Alert | 5 min read | 08.26.26
D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances
Client Alert | 5 min read | 08.26.26
