TINA Threshold Raised but Broader Data Requests Likely
Client Alert | 1 min read | 10.05.10
Effective October 1, a "clarified" FAR regulation regarding compliance with the Truth in Negotiations Act raises the threshold for providing certified cost or pricing data from $650,000 to $700,000 for covered contract and subcontract awards and modifications. The new regulation, which the Civilian Agency Acquisition and Defense Acquisition Regulations Councils say merely contains clarifications and "neither expands nor diminishes the existing right of contracting officers to request cost or pricing data whether certified or other than certified" appears likely to precipitate expanded and more aggressive contracting officer requests for non-certified judgmental data, even when certified cost or pricing data are required, and, particularly with respect to "excepted" procurements for commercial items and services, for (non-certified) cost data.
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Client Alert | 5 min read | 09.03.26
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.
Client Alert | 6 min read | 09.03.26
FDA Seeks Input for Regulating GenAI-Powered Medical Devices
Client Alert | less than 1 min read | 09.03.26
SBA Proposal to Overhaul Size Standards Would Transform Federal Government Contracting
Client Alert | 5 min read | 09.02.26
DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement

