CAS Pension Requirements In The Market Meltdown
Client Alert | less than 1 min read | 10.13.08
The drastic decline in the market value of the assets in defined-benefit pension plans is causing many contractors to review their options, including the possibility of partially or completely curtailing the accrual of future benefits under those plans. A complete curtailment of future benefits is a "segment closing" that would require adjustment of prior costs under CAS 413.50(c)(12) (producing a credit or refund to the Government if the plan is in surplus and a payment to the contractor if the plan is in deficit) and any decision to change future benefits may affect future costs, requiring timely disclosure in current negotiations under the Truth in Negotiations Act.
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
