DCAA Issues (Mis)Guidance on Expressly Unallowable Costs
Client Alert | 1 min read | 02.23.15
On January 7, 2015, DCAA issued guidance to auditors for determining whether certain costs are "expressly unallowable" – and therefore subject to penalties – even when the regulations "do not state in direct terms that the cost is unallowable." This guidance, which is intended to "enhance" the equally troubling December 18 guidance to similar effect, is inconsistent with the CAS 405 definition of "expressly unallowable cost" (i.e., "a particular item or type of cost which, under the express provisions of an applicable law, regulation, or contract, is specifically named and stated to be unallowable") and will likely lead to confusion in the audit process and undoubtedly result in DCAA auditors assessing more penalties against contractors on dubious grounds.
Insights
Client Alert | 4 min read | 09.12.25
SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal
On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.
Client Alert | 6 min read | 09.11.25
U.S. Department of Commerce Partially Relaxes Export Controls on Syria
Client Alert | 9 min read | 09.11.25
Client Alert | 1 min read | 09.10.25
