Substantial Changes To CAS Administration Regulations
Client Alert | 1 min read | 03.16.05
Final rules, effective April 8, 2005, concerning proposed changes to CAS administration requirements that have been pending since April 2000 were promulgated on March 9, 2005 (70 Fed. Reg. 11743-61). The new regulations will be discussed in detail at the upcoming OOPS/WOOPS programs on March 31-April 1/April 14-15, but some of the highlights include:
- When there is a CAS noncompliance, contract price adjustments may be required for closed contracts and closed years,
- Improvement in the definition of "desirable" and "required" changes may permit contractors to avoid price adjustments,
- Retroactive accounting changes are permitted in limited circumstances,
- Widely criticized proposals to prohibit offsets between FFP and flexibly-priced contracts were abandoned, and
- Estimates to complete rather than original cost estimates must be used to determine cost impact on FFP contracts.
Insights
Client Alert | 4 min read | 08.25.26
DOJ Signals Increased Antitrust Scrutiny of Algorithmic Pricing in Willow Bridge Decision
Algorithmic pricing tools commonly used by businesses to increase efficiency and profits are under increasing antitrust scrutiny. This summer, federal regulators, state attorneys general, and state legislatures grappled with competing businesses providing nonpublic, competitively sensitive data to common algorithmic platforms. The Third Circuit deepened an emerging circuit split with the Ninth Circuit on algorithmic pricing liability, reviving antitrust claims against Atlantic City casino-hotels in a decision with direct implications for any company that uses a common pricing platform. See Crowell’s recent client alert. And New Jersey enacted two landmark laws—the FAIR Act and the Fair Price Protection Act—directly regulating algorithmic rent-setting and surveillance pricing. See Crowell’s recent client alert.
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FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
