Thomas A. Lemmer

Dentons

Articles

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DoD thresholds for cost and pricing data poised to increase to $2M, reducing contractor risks of defective pricing and CAS liability

USA - April 24 2018 In just over two months, the dollar threshold triggering the requirement for certified cost and pricing data under Federal Acquisition Regulation…

Steven M. Masiello

ASBCA alters the definition of expressly unallowable costs implicating penalties

USA - June 20 2017 The Armed Service Board of Contract Appeals (“ASBCA”), in its recent decisions, continues to back away from its previous definition of expressly…

Tess Gosda, Steven M. Masiello

DoD issues class deviation to roll-back IR&D technical interchange requirements

USA - December 6 2016 On December 1, 2016, the Office of the Under Secretary of Defense Acquisition, Technology and Logistics issued a class deviation for the Department of…

Jeremiah J. McIntyre III, Steven M. Masiello, Gale R. Monahan

IR&D technical interchanges: DCMA bows out, leaving OSD to go it alone—to contractors’ detriment

USA - December 1 2016 On November 21, 2016, the Defense Contract Management Agency (DCMA) issued guidance to its contracting officers instructing them to refer contractors’…

Steven M. Masiello, Gale R. Monahan

Proposed IR&D DFARS rule would competitively punish technology innovators

USA - November 7 2016 Understanding that it will punish innovative contractors for engaging in independent research and development (IR&D) and taking on risks that would…

Jeremiah J. McIntyre III, Steven M. Masiello, Gale R. Monahan