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Erin N. Rankin

Partner
Partner
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VCardLinkedIn

Areas of Focus

Overview

Erin Rankin has extensive experience guiding government contractors through complex cost and pricing compliance issues, including the Cost Accounting Standards, cost allowability, Truthful Cost and Pricing (formerly Truth in Negotiations or TINA), and DCAA audit findings. Erin is also a skilled litigator, having represented numerous clients before the Armed Services and Civilian Boards of Contract Appeals and the Court of Federal Claims. She has also defended companies against False Claims Act allegations, conducted internal investigations, and advocated for clients in mandatory disclosures and suspension and debarment proceedings.

As a trusted advisor to government contractors, Erin provides valuable counsel to clients on all aspects of the FAR and the Uniform Guidance in connection with the administration, performance, and closing out of government contracts, grants, and cooperative agreements.

Erin is a partner in Crowell’s Government Contracts group and based in the Washington, D.C. office.

Career & Education

    • The George Washington University Law School, J.D., with honors, 2009
    • The Ohio State University, B.A., magna cum laude, 2006
    • The George Washington University Law School, J.D., with honors, 2009
    • The Ohio State University, B.A., magna cum laude, 2006

    • District of Columbia
    • Virginia
    • U.S. Court of Appeals for the Federal Circuit
    • U.S. Court of Federal Claims
    • District of Columbia
    • Virginia
    • U.S. Court of Appeals for the Federal Circuit
    • U.S. Court of Federal Claims

Erin's Insights

Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”...

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Representative Matters

  • Ongoing representation of a major Defense contractor in ASBCA appeals of government claims unilaterally setting indirect cost rates and claiming repayment for allegedly unallowable indirect costs.
  • Successful representation of a major Defense contractor in an ASBCA appeal of a government claim seeking recovery of allegedly unallowable costs incurred to continue contract performance during the COVID-19 pandemic, resulting in withdrawal of government's claim.
  • Successful resolution of a show cause letter from the Navy Suspension and Debarment Official, with no action, regarding alleged accounting and estimating system deficiencies.
  • For numerous government contractors, successful representation resulting in zero-dollar settlements of actual and threatened government claims for alleged noncompliance with CAS 403, CAS 410, and CAS 420.
  • Represented numerous government contractors to successfully settle proposed pension cost adjustments following segment spinoffs or pension plan freezes under CAS 413.
  • Represented a Defense contractor through evidentiary hearing and obtained a judgment entitling the contractor to disputed termination for convenience costs, including precontract costs under FAR 31.205-32.
  • Represented a Department of Energy contractor in False Claims Act litigation in federal district court and a parallel Contract Disputes Act proceeding before the Civilian Board of Contract Appeals, resulting in dismissal of the government’s allegation that the contractor charged unallowable home office expenses.
  • Represented a Defense contractor in a multimillion-dollar government claim for costs disallowed under FAR 31.201-2(d) (supporting documentation), FAR 31.201-3 (reasonableness), FAR 31.205-46 (travel costs), and the Fly America Act, resulting in a withdrawal of the contracting officer’s final decision.
  • Represented a defense technology company in successfully resolving a dispute with the Department of Defense regarding compliance with the Truth in Negotiations Act.
  • Represented a major defense contractor in negotiating the settlement of the cost impact of a change to accounting practices.
  • Represented a government contractor in termination for default proceedings before the Civilian Board of Contract Appeals, resulting in conversion into a termination for convenience.
  • Represented a NASA contractor in successfully resolving a contract dispute relating to labor costs incurred under a services contract in proceedings before the Armed Services Board of Contract Appeals.

Erin's Insights

Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”...

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Insights

Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

Client Alert | 2 min read | 05.01.26

New Executive Order Promoting Fixed Price Contracting: What It Means for Federal Contractors

Speaking Engagement | 04.23.26

"Cost and Pricing: Making Cents Out of So Much Change," OOPS 2026, Tyson's Corner, VA.

Speaking Engagement | 01.08.26

"What Will the New Year Bring in 2026?" Crowell & Moring Webinar.

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Practices

Erin's Insights

Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”...

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