DOE Solution To Underfunded Pension Plans: Don't Pay For Them
Client Alert | 1 min read | 05.03.06
In a "notice" issued April 27, 2006 (http://directives.doe.gov/pdfs/doe/doetext/neword/351/n3511.pdf), DOE announced that "after a date to be negotiated with each Contractor, but no later than March 1, 2007," DOE will try to incorporate provisions in its contracts that would appear to make defined-benefit pensions and retiree medical benefits for new employees unallowable and prohibit reimbursement for plan enhancements unless approved in advance by DOE. It seems unlikely that DOE would have the authority to impose these requirements on existing contracts unilaterally, and some of them, particularly restrictions on the allowability of costs required by collective bargaining agreements, would conflict with existing FAR cost allowability rules.
Insights
Client Alert | 8 min read | 09.09.25
On September 5, 2025, the Federal Trade Commission (“FTC”) withdrew its appeals of decisions issued by Texas and Florida federal district courts, which enjoined the FTC from enforcing a nationwide rule banning almost all noncompete employment agreements. Companies, however, should not read this decision to mean that their noncompete agreements will no longer be subjected to antitrust scrutiny by federal enforcers. In a statement joined by Commissioner Melissa Holyoak, Chairman Andrew Ferguson stressed that the FTC “will continue to enforce the antitrust laws aggressively against noncompete agreements” and warned that “firms in industries plagued by thickets of noncompete agreements will receive [in the coming days] warning letters from me, urging them to consider abandoning those agreements as the Commission prepares investigations and enforcement actions.”
Client Alert | 12 min read | 09.09.25
Client Alert | 7 min read | 09.08.25
California’s Climate Disclosure Laws Continue to Roll Forward
Client Alert | 3 min read | 09.08.25
RADV Audits: Implications and Recommendations for Medicare Advantage Organizations
