GAO Reports Deficiencies In DCAA Audit Reports
Client Alert | 1 min read | 09.24.09
After a review that was focused on DCAA offices that issued primarily "clean" opinions and reports, GAO concluded in testimony delivered to the Senate Committee on Homeland Security and Government Affairs on September 23 that there were serious quality problems in 65 of 69 DCAA audit report it reviewed (with minor problems in the other 4) and recommended measures to "strengthen" the role of DCAA in the process. Because of the admittedly biased sample used by GAO, the GAO report does not address or acknowledge quality problems in DCAA findings that are adverse to contractors, although GAO did note that DCAA's decision last year to report contractor systems as either "adequate" or "inadequate," eliminating "inadequate-in-part" findings, could unfairly penalize contractors that do not have material or serious deficiencies and recommended that DCAA seek "outside expertise" to develop audit policy and training on audit standards.
Insights
Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
