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Compensation Caps Rule Finalized

Client Alert | less than 1 min read | 11.02.16

On September 30, 2016, a more than two-year-old interim rule on the allowable cost limits of contractor and subcontractor employee compensation became final. Under this rule, which "applies to costs incurred on contracts award on or after June 24, 2014," compensation costs are capped at $487,000 (adjusted annually in accordance with the Employment Cost Index), though agencies may establish narrow exceptions for "scientists, engineers, or other specialists."

Insights

Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....