DCAA's Use of a Statistically Invalid Analysis for Testing Compensation Reasonableness
Client Alert | less than 1 min read | 02.03.12
The ASBCA in J.F. Taylor, Inc. (Jan. 18, 2012) rejected DCAA’s disallowance of executive compensation, based primarily on the credibility of differing expert opinions. The board concluded that the standard DCAA analysis relying on a “rule of reason” that permits compensation within 10% of the 50th percentile of an unweighted average of multiple surveys with different sample sizes is statistically invalid, at least in part because the contractor’s expert was credible and the government’s, who had included in his resume what was arguably a mail order PhD from a South African “university,” was not.
Insights
Client Alert | 7 min read | 06.26.26
Federal Roundup: Updates for PBMs and Medicare Advantage Organizations
In June 2026, federal regulators and lawmakers continued their efforts to improve drug affordability through targeted reforms. These recent developments will primarily impact pharmaceutical manufacturers, managed care organizations, and pharmacy benefit managers (PBM) serving Medicare Part D program members. PBMs, Medicare Advantage organizations, and Part D sponsors should monitor these changes in the interest of maintaining compliance and providing input on regulatory proposals that may influence their business operations or compensation structures in the future.
Client Alert | 6 min read | 06.26.26
Client Alert | 4 min read | 06.25.26
Twin Executive Orders Seek to Spur Quantum Leap in Technology and Cybersecurity
Client Alert | 7 min read | 06.24.26
