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Statute of Limitations Runs from Receipt of Auditable Information

Client Alert | 1 min read | 04.04.12

The six-year statute of limitations on contract claims begins to run when either party's cause of action "accrues," defined in FAR 33.201 as "the date when all events, that fix the alleged liability of either the Government or the contractor and permit assertion of the claim, were known or should have been known." Several prior decisions have held that a government claim accrued no later than the date on which it is identified and quantified in an audit report, but in Raytheon Co. v. U.S. (Apr. 02, 2012), the Court of Federal Claims held that the government claim had accrued, not when the costs at issue were first audited (2003), but instead when Raytheon submitted to the government all of the information that was needed to audit the costs and assert a claim (1999).

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Client Alert | 4 min read | 10.21.25

Pivot Point for 340B: HRSA Rebate Model Pilot Program Approaches Launch

The deadline for Department of Health and Human Services (“HHS”) to notify approved manufacturers of acceptance into the 340B Rebate Model Pilot Program has passed, and stakeholders across the healthcare industry should start planning for compliance and operational changes. The Model Pilot Program may also face legal challenges that could delay or disrupt implementation....