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 | 5 min read | 01.27.25
After Trump Executive Orders, FDA Removes Diversity Guidance From Website
Days after President Trump issued an executive order (EO) taking aim at diversity, equity, and inclusion (DEI) programs and prohibiting federal recognition of gender identity apart from biological sex, previously issued draft guidance on diversity in clinical trials was removed from the website of the U.S. Food and Drug Administration (FDA). While the removed guidance was in draft form, it is highly unusual for FDA to revoke or alter draft guidance without issuing a statement or further guidance. This move raises questions about the applicability of statutory obligations to submit clinical trial Diversity Action Plans and the agency’s current thinking on best practices for clinical development.
Client Alert | 8 min read | 01.27.25
Client Alert | 5 min read | 01.27.25
Client Alert | 2 min read | 01.27.25
State Department Pauses Almost All Foreign Assistance Funding
