DCAA "Independence"
Client Alert | less than 1 min read | 03.24.09
The Defense Contract Audit Agency (DCAA) has revised its policy concerning "unsatisfactory conditions related to actions of Government Officials" to provide that "significant and serious" disagreements with actions by government officials, including contracting officers, will be reported directly to the Inspector General rather than to the Government official's management chain, as had been the policy in the past (Mar. 13, 2009). Prior guidance had already required direct reporting of "suspected irregularities" such as criminal violations, and this guidance appears to be intended to cover discretionary decisions that the auditors believe will "result in substantial harm to the Government or taxpayers, or that frustrate public policy."
Insights
Client Alert | 5 min read | 09.03.26
The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events.
Client Alert | 6 min read | 09.03.26
FDA Seeks Input for Regulating GenAI-Powered Medical Devices
Client Alert | less than 1 min read | 09.03.26
SBA Proposal to Overhaul Size Standards Would Transform Federal Government Contracting
Client Alert | 5 min read | 09.02.26
DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement
