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Pass-Through Cost Proposed Rule

Client Alert | less than 1 min read | 07.11.14

The government issued on July 10, 2014, a proposed rule that would require all agencies to justify contract awards, except those to small businesses, that propose to pass through more than 70 percent of the total cost of work to subcontractors by considering the availability of alternative contract vehicles and the feasibility of contracting directly with the proposed subcontractor(s) and to make a written determination that the selected contracting approach is in the best interest of the government. Written comments on the proposed rule are due September 9, 2014.


Insights

Client Alert | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....