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IR&D Reporting Requirements Reinstated

Client Alert | 1 min read | 01.30.12

In a final rule published today, the DFARS were amended to reinstate a requirement that was eliminated from the regulations in the early 1990s, providing that as a condition of allowability for Independent Research and Development (IR&D) costs, major contractors must submit to DoD at least annually technical descriptions of the IR&D projects that the contractor claims as allowable. In response to criticism of a draft regulation proposing a $50,000 coverage threshold, the final rule limits mandatory reporting to “major contractors” that allocate more than $11 million annually to “covered contracts” (a term that excludes fixed-price contracts without cost incentives), leaves largely to the contractor’s discretion how much detail needs to be reported in the on-line template through which the reports must be submitted, encourages voluntary reporting by contractors not subject to the mandatory requirement, and promises that the reports will be exempt from disclosure under the Freedom of Information Act.

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Client Alert | 4 min read | 11.10.26

D.C. District Court Upholds CMS’s 2020 Organ Procurement Rule

It’s been about a month since the U.S. District Court for the Middle District of Florida upheld the Centers for Medicare and Medicaid’s (CMS) final rule governing organ procurement organizations (OPM). (See our previous Client Alert here.) The U.S. District Court for the District of Columbia followed suit. In contrast to the Florida decision, the D.C. decision was brief and to the point. The rule establishes a competitive model for classifying OPOs under the following three tiers. ...