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 | 11.18.25
DOJ Announces Major Enforcement Actions Targeting North Korean Remote IT Worker Schemes
On November 14, 2025, the U.S. Department of Justice (DOJ) announced a sweeping series of enforcement actions, including four guilty pleas and more than $15 million in civil forfeitures against the Democratic People’s Republic of Korea (DPRK or North Korea) for remote information technology (IT) worker schemes. These actions underscore the federal government’s escalating focus on the exposure of U.S. companies to North Korean IT worker infiltration, following a series of U.S. Government action against the DPRK.
Client Alert | 6 min read | 11.18.25
Client Alert | 2 min read | 11.14.25
Client Alert | 6 min read | 11.14.25
Microplastics Update: Regulatory and Litigation Developments in 2025
