Failure to Consider CAS Materiality Criteria Dooms Gov’t Claim
Client Alert | 1 min read | 11.10.16
In Raytheon Co. (ASBCA Aug. 9, 2016), a case involving disallowed cost increases following voluntary accounting changes, the board ruled that the CO violated FAR 30.602 and abused her discretion by considering only the amount of the dollar impact of the accounting changes and, thus, “fail[ed] to analyze the materiality of the cost impacts at issue” pursuant to the criteria set out in CAS 9903.305. Noting (without deciding) that a cost impact of less than 0.005 percent across affected contracts (roughly $142 per contract) might not be “material,” the board held that the government cannot recover on its claim when the CO “simply disregard[s],” rather than evaluates, the CAS materiality factors.
Insights
Client Alert | 8 min read | 01.17.25
Cyber For All: Proposed Rule Introduces Government-Wide CUI Cybersecurity Requirements
On January 15, 2025, the FAR Council released a proposed rule (FAR CUI Rule) that would amend the FAR to implement federal government-wide Controlled Unclassified Information (CUI) cybersecurity, training, and incident reporting requirements for government contractors and subcontractors. The rule’s key cybersecurity requirements closely mirror the Department of Defense’s Cyber Maturity Model Certification (CMMC) program (for example, compliance with National Institute of Standards and Technology Special Publication 800-171, Revision 2), but broaden the scope to include contractors and subcontractors working across all federal agencies. The Rule is intended to standardize the handling of CUI by federal government contractors and subcontractors in accordance with Executive Order 13556, including by:
Client Alert | 2 min read | 01.17.25
End of the Road: FHWA Rescinds Longstanding Buy America Waiver for Manufactured Products
Client Alert | 3 min read | 01.17.25
