‘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
Partner
She/Her/Hers
Insights
Client Alert | 8 min read | 07.16.25
In our first alert in this weekly series on the EU Pharma Package we provided some important background and general information about the status of the Pharma Package and how the trilogues work, and in the second alert we discussed the proposed changes to regulatory data protection.
Client Alert | 2 min read | 07.15.25
Client Alert | 10 min read | 07.15.25
Fueling The Future: Understanding The EU’s Clean Industrial Deal State Aid Framework (CISAF)
Client Alert | 5 min read | 07.14.25
The European Commission issues competition guidance in the transport sector
