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).
Contacts
Insights
Client Alert | 3 min read | 01.26.26
8(a) Participants – and the 8(a) Program – Under the Microscope or on the Chopping Block
The Small Business Administration (SBA) has rolled out changes to its 8(a) Program even as it suspends 8(a) participants for failure to respond to the SBA’s December 5, 2025 8(a) audit letters.
Client Alert | 3 min read | 01.21.26
Atlantic Biologicals Opioid DPA: DOJ Continues Ramp Up of Criminal Corporate Healthcare Enforcement
Client Alert | 3 min read | 01.21.26
FedRAMP Proposes Updates to Authorization Process—Six New RFCs Released for Public Comment
Client Alert | 3 min read | 01.20.26
DoW Joins SBA’s Fight Against Alleged Pass-Through Fraud in the 8(a) Program

