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Separate CAS Noncompliances May Get Separate SOL

Client Alert | 1 min read | 01.22.14

In Appeal of Fluor Corp., the ASBCA held that the government's claim relating to an alleged CAS 403 noncompliance "was a continuing claim inherently susceptible to being broken down into a series of independent distinct events," namely, each payment by the government for a CAS-non-compliant billing. Thus, the board held that, under the CDA's statute of limitations, the government "knew or should have known" that it had a claim against the contractor as of the date the compliance audit was completed (for amounts paid before that date), but that claims for the same alleged CAS noncompliance in subsequent years would not accrue until the amounts at issue for those years had been billed and paid, a result that may save some government claims from the CDA's 6-year SOL (previously discussed here, here, here, here, and here).


Insights

Client Alert | 3 min read | 10.13.25

Upcoming Massachusetts Pay Transparency Requirements

Commencing October 29, 2025, Massachusetts will join 14 other U.S. states in requiring certain employers to disclose wage pay ranges both in their public job postings and internally to employees who request the information. The requirement is mandated by the Massachusetts law entitled “An Act Relative to Salary Range Transparency” which aims to increase pay transparency and equity in the Commonwealth....