Executive Compensation Limits Expanded
Client Alert | 1 min read | 01.05.12
Section 803 of the National Defense Authorization Act of 2012, signed by the President on December 31, 2011, expands the existing limit on "senior executive" compensation to cover all employees and purports to apply the new allowability limitation effective January 1, 2012, to existing contracts, although "the Secretary of Defense may establish one or more narrowly targeted exceptions for scientists and engineers upon a determination that such exceptions are needed to ensure that the Department of Defense has continued access to needed skills and capabilities." The most recent cap published by the Office of Federal Procurement Policy was $693,951 for 2010 (no cap was published in 2011, apparently for political reasons), so as a practical matter the expansion of the cap to all employees is likely to have limited impact, but the provision purporting to apply the new limit to existing contracts is almost certainly unenforceable.
Insights
Client Alert | 4 min read | 01.07.26
On December 17, 2025, the U.S. Food and Drug Administration (FDA) issued a request for information (RFI) on a proposal designed to help the FDA engage more directly with innovative, venture-backed companies focused on biotechnology, medical devices, AI, and regulatory technology.[i]The RFI includes 19 questions, with responses due by 2:00 p.m. ET on January 18, 2026.
Client Alert | 3 min read | 01.07.26
CMMC for AI? Defense Policy Law Imposes AI Security Framework and Requirements on Contractors
Client Alert | 3 min read | 01.07.26
New Year, Same CIPA Uncertainty – When Will the Appellate Courts Enter the Chat?
Client Alert | 11 min read | 01.07.26
