Making a List and Checking It Twice: New Rule Requires "Adequacy Checklist" with Forward Pricing Rate Proposals
Client Alert | less than 1 min read | 01.09.15
On December 11, 2014, DoD issued a final rule to instruct COs to request that contractors submit a Forward Pricing Rate Proposal "Adequacy Checklist" when submitting their FPRP. Under the rule, both the FPRP and the Adequacy Checklist are due at least 90 days before the proposed effective date of the rates, and DoD cautioned that "the proposed rates are based on forecasts and contractors must provide updates whenever the validity of the agreement may be affected."
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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
