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CAS-covered Contract Not "Affected" By Accounting Change

Client Alert | less than 1 min read | 07.03.07

In its first addressing of the definition of "affected contracts" under the CAS regulations in a situation that arises with surprising frequency, the ASBCA in Lockheed Martin Corp. (June 28, 2007), a case handled by Crowell & Moring, has held that a CAS-covered contract awarded before a change in accounting practice was disclosed and implemented, but completely repriced with full disclosure of the change, is not "affected" by the change and is not subject to price adjustment to reflect the impact of the change. The decision also includes guidance about the meaning of "desirable" changes that should be helpful to contractors.

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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....