DFARS Excessive Pass-Through Cost Rule Modified
Client Alert | 1 min read | 05.13.08
Effective May 13, 2008 (73 Fed. Reg. 27464), the widely-criticized interim DFARS rules about "excessive pass-through costs" published last April were modified in yet another interim rule to address the confusion created by the interim rules. The most important features of the new interim rules are in the prefatory comments, which emphasize repeatedly that the requirement for reporting when subcontract effort will exceed 70 percent applies both before and after award, but is only a reporting requirement, not a threshold for coverage, and that the rules do not apply to any contract, no matter what the subcontract content, where the contractor demonstrates "added value," a term that is defined in the interim regulations to include performance of "subcontract management functions that the Contracting Officer determines are a benefit to the Government (e.g., processing orders of parts or services, maintaining inventory, reducing delivery lead times, managing multiple sources for contract requirements, coordinating deliveries, performing quality assurance functions)."
Insights
Client Alert | 4 min read | 05.07.25
FTC Cracks Down on AI Model’s AI Detection Claims
The Federal Trade Commission (FTC) issued a proposed order prohibiting Workado, LLC, from advertising the accuracy of its artificial intelligence (AI) detection products unless it possesses competent and reliable evidence demonstrating that the model performs as depicted.
Client Alert | 3 min read | 05.07.25
NIH Continues Grant Awards Overhaul With New Limitations on Foreign Subawards
Client Alert | 10 min read | 05.06.25
Client Alert | 1 min read | 05.05.25