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 | 4 min read | 09.12.25
SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal
On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.
Client Alert | 6 min read | 09.11.25
U.S. Department of Commerce Partially Relaxes Export Controls on Syria
Client Alert | 9 min read | 09.11.25
Client Alert | 1 min read | 09.10.25
