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New Rule Requires Contractors to Report Data for DoD Service Contracts in SAM

Client Alert | 1 min read | 07.09.21

On July 9, 2021, the U.S. Department of Defense (DoD) published a Final Rule to require contractors to report data in the System for Award Management (SAM) on an annual basis when they are awarded a DoD contract or task order that: (1) is valued in excess of $3 million, and (2) is for logistics management services, equipment related services, knowledge-based services, or electronics and communications services. When applicable, contractors will be required to annually report: (1) the total dollar amount invoiced for, and (2) the total number of direct labor hours expended on services performed under the contract or task order during the preceding fiscal year. The total number of direct labor hours reported to SAM should be the total of both the contractor hours and its first-tier subcontractors’ hours.

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Client Alert | 5 min read | 09.03.26

DOT Final Rule Narrows Airline Delay and Cancellation Reporting Obligation Under FAA Reauthorization Act of 2024

The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events....