Enhanced Requirements for Cost-Reimbursement Contracting
Client Alert | 1 min read | 03.16.11
As required by the FY 2009 DOD Authorization Act, the Federal Acquisition Regulation has been amended effective March 16, 2011 (76 Fed. Reg. 14543), to add new provisions controlling the Government's decision to award cost-reimbursement contracts. The enhanced regulations focus on the Government's internal processes, but the provisions most likely to affect contractors directly are the requirement for appointment of a qualified contracting officer's representative (COR) or contracting officer's technical representative (COTR) prior to award of cost-reimbursement contracts and assignment on a non-delegable basis to the cognizant federal agency official (CFAO -- generally the ACO for DOD contractors) of responsibility for determining the adequacy of the contractor's accounting system during the entire period of contract performance, with no express limit in the regulation as to the type of contract covered by that provision.
Insights
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About one year ago, the European Court of Justice (CJEU) ruled in its landmark Illumina/Grail judgment that the European Commission could not accept merger referrals from national competition authorities under Article 22 of the EU Merger Regulation (EUMR) unless those authorities had jurisdiction to review the transaction themselves (see our previous alert).
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