Limitation on Mark-Up of Subcontractor Costs
Client Alert | less than 1 min read | 04.30.07
In an interim rule effective immediately, the Defense Department amended DFARS on April 26, 2007 to permit the Government to "disallow" (including on firm-fixed price contracts) "excessive pass through charges" on subcontracts where the total subcontract costs exceeds 70 percent of the contract value. "Excessive" charges are defined to include costs and profit that the contractor cannot demonstrate to the contracting officer add something other than "no or negligible" substantive value to performance, so any contractor with an accounting practice that allocates G&A to subcontract costs could run afoul of these rules.
Insights
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies.
Client Alert | 8 min read | 04.27.26
Client Alert | 5 min read | 04.27.26
Drift Protocol Exploit: Why “Social Trust” Is the Newest Cybersecurity Gap
Client Alert | 4 min read | 04.27.26
Gaming Addiction Litigation: Turner v. Epic Games & Roblox and What It Means for the Industry
