1. Home
  2. |Insights
  3. |OMB and DoD Do Sequestration Two-Step

OMB and DoD Do Sequestration Two-Step

Client Alert | less than 1 min read | 08.13.12

On August 1, 2012, Acting OMB Director Jeffrey Zients and Deputy Secretary of Defense Ashton Carter testified before the House Armed Services Committee regarding the potential impacts of sequestration set to begin on January 2, but declined to spell out whether OMB would apply sequestration at the program, project, or activity level – the key to determining whether agencies would have some discretion to pick and choose among contracts. Sec. Carter hinted that DoD would follow that approach, stating that the DoD leadership "will take advantage of any flexibility [they] can find" to reach the target cuts, although any such flexibility is already restricted by the Administration's announcement that payroll accounts for military personnel would be exempt.

Insights

Client Alert | 4 min read | 03.05.26

DOL’s Proposed Independent Contractor Rule Reverts to Prioritize Two Core Factors – Likely Limiting Misclassification Claims by Contractors

The U.S. Department of Labor (DOL) has proposed another revision to independent contractor regulations, one that would provide for more leeway in classifying workers as contractors. DOL’s proposed rule, published on February 26, 2026, would rescind the Biden DOL’s March 2024 independent contractor regulation and reinstate a framework substantially tracking the prior Trump rule of January 2021. The proposed rule would also apply the narrower analysis to worker classifications under the Family and Medical Leave Act (FMLA) and the Migrant and Seasonal Agricultural Worker Protection Act (MSPA). The comment period closes in late April 2026; until then, the 2024 rule remains in effect for purposes of private litigation....