Help Wanted: Bounty Hunters
Client Alert | less than 1 min read | 03.22.10
In a memorandum dated March 10, 2010, President Obama directed the heads of all executive departments and agencies to expand their use of recovery audits, now called “Payment Recapture Audits,” in order to identify and reclaim from contractors the funds associated with improper payments (e.g., duplicate payments, payments for services not rendered, overpayments, and payments to fictitious vendors) and has also directed OMB to develop guidance within 90 days for carrying out the requirements of the memorandum. He points approvingly to use of professional and specialized auditors whose compensation is tied to their findings of such overpayments.
Insights
Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.
Client Alert | 3 min read | 07.15.26
Client Alert | 3 min read | 07.14.26
Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine
