Allowability of IR&D Costs: Dis-inflation Run Amok
Client Alert | less than 1 min read | 03.09.11
DOD has issued a proposed amendment to DFARS 231.205-18 (Mar. 2, 2011) that would condition the allowability of independent research and development costs on the reporting of unspecified information about individual projects at least annually and again on completion of projects, using DOD on-line reporting forms. The proposed rule would apply to all contractors with annual IR&D costs in excess of $50,000, an amount that is less than 1% of the threshold in effect in 1990 for reporting IR&D projects under the prior regulatory regime, a mandatory reporting requirement that was completely abolished in 1996.
Insights
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
