Double Take: The DoD OIG Recommends Attempting to Recoup $43 Million in Purportedly Expressly Unallowable Costs Not Previously Disallowed
Client Alert | 1 min read | 02.13.20
On January 14, 2020, the Department of Defense (DoD) Office of Inspector General (OIG) released a report examining whether Defense Contract Management Agency (DCMA) contracting officer (CO) rejections of recommendations by the Defense Contract Audit Agency (DCAA) to assess penalties on $43 million in unallowable costs identified in 18 DCAA audit reports complied with the Federal Acquisition Regulation (FAR), DoD Instructions, and agency policy. The OIG did not take issue with the fact of the COs’ disagreements, nor did it take a position on the merits of the COs’ determinations. But the OIG did conclude that the COs did not adequately document their reasons for rejecting DCAA’s penalty recommendations. Accordingly, the OIG recommended that DCMA reevaluate the COs’ decisions not to assess penalties on the $43 million, take actions to reclaim any expressly unallowable costs not previously disallowed, and collect from the contractors any penalties due to the Government. DCMA stated that it would review the audit reports and attempt to recoup costs and/or penalties and interest that DCMA COs previously decided not to pursue, as appropriate.
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On June 22, 2026, President Trump signed two executive orders, “Securing the Nation Against Advanced Cryptographic Attacks” (Quantum Security EO) and “Ushering in the Next Frontier of Quantum Innovation” (Quantum Innovation EO), marking the most significant federal action on quantum technology since the Quantum Computing Cybersecurity Preparedness Act of 2022, which directed agencies to harden their information systems against quantum-enabled hacking. The orders seek to speed the development of quantum computers, which are advanced processors that can calculate multiple possibilities simultaneously and thus solve problems exponentially faster than traditional computers. At the same time, the orders look to protect against the danger that quantum technology can “break” traditional encryption by easily decoding it. Of particular note for government contractors, the Quantum Security EO directs agencies to update federal acquisition regulations to require contractors by 2031 to adopt information processing standards that resist quantum-enabled codebreaking.
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