It’s Back – DCAA’s Non-Defense Audit Authority Revived
Client Alert | less than 1 min read | 11.03.16
A recent DCAA policy memorandum lifted the moratorium on DCAA performing non-Defense audits, which (as discussed here) effectively applied only to incurred cost audits. Specifically, because DCAA has purportedly "met the requirement of less than 18 months of incurred cost inventory" outlined in the 2016 National Defense Authorization Act as of October 1, 2016, DCAA "may again provide full audit support for non-Defense agencies" and the Operations Directorate "has coordinated at the Executive level with [its] reimbursable customers to inform them that [its] audit services can resume."
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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
