1. Home
  2. |Insights
  3. |Cost Disallowance Claim Accrued When the Government Paid Invoices

Cost Disallowance Claim Accrued When the Government Paid Invoices

Client Alert | 1 min read | 09.11.18

In United Liquid Gas Co. v. GSA (July 12, 2018), the Civilian Board of Contract Appeals found that the government’s cost disallowance claim was untimely under the Contract Disputes Act’s six-year statute of limitations. Following an audit, GSA filed a $3.3 million claim alleging that the contractor overbilled GSA on a fixed-price per gallon propane contract. The Board held that GSA’s claim began to accrue on the date that the Government paid each invoice. GSA argued unsuccessfully that, before the audit, it could not have known of the overbilling because the invoices were paid by a separate agency (the Defense Finance and Accounting Service). The Board responded that GSA was “obligated to monitor [the] payments” and thus “should have known about the overpayment[s].” Because each invoice payment was treated as a separate event for claim accrual purposes, the Board denied as time-barred roughly $280,000 of GSA’s claim that involved payments more than six years before the claim was filed.

Insights

Client Alert | 4 min read | 05.01.26

Federal Court Blocks Trump Administration Policies Restricting Wind and Solar Permitting

A coalition of regional clean energy trade associations — including RENEW Northeast, Alliance for Clean Energy New York, Southern Renewable Energy Association, and Interwest Energy Alliance — along with the Green Energy Consumers Alliance (GECA), filed suit in December 2025 against the Department of the Interior (DOI), the Bureau of Land Management, the Bureau of Ocean Energy Management, the U.S. Fish and Wildlife Service (USFWS), and the Army Corps of Engineers. The complaint alleged that five agency actions, issued in response to a series of executive orders and presidential memoranda beginning on January 20, 2025, violated the Administrative Procedure Act (APA) by arbitrarily halting or restricting federal permitting for wind and solar energy projects. Plaintiffs sought a preliminary injunction to halt enforcement of these policies while the litigation proceeds. See Renew Northeast, et al. v. U.S. Dep’t of Interior, et al., No. 25-cv-13961-DJC,  (D. Mass. Apr. 21, 2026) ECF Dkt. 89....