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Brown Rudnick LLP
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  • 04/10/2014
  • How easy is it to misplace $6 billion?

    Recently, the State Department’s Office of Inspector General (“OIG”) made public an internal memorandum stating that over the last six years, the OIG has identified more than $6 billion in State Department contracts “in which contract files were incomplete or could not be located at all.”¹  Among the highlights (lowlights?) of the report were findings that in an auditing sample of 115 contracts for the U.S. mission in Iraq alone, more than 70% of the contract files were missing or deficient.²

  • 04/04/2014
  • DOE Introduces Proposed Rule to Supplement Income of Accountants and Consultants

    The Department of Energy (“DOE”) is taking a page from the 2012 playbook of the Department of Defense (“DoD”).  In February 2012, DoD issued a final rule that introduced new Defense Federal Acquisition Regulation Supplement (“DFAR”) clauses that defined contractor business systems and authorized the contracting officer to withhold certain payments for contracting officer-identified “significant deficiencies” in the contractor’s business systems.  DOE recently published a proposed rule that, if finalized, will introduce similar new clauses to the Department of Energy Acquisition Regulation (“DEAR”).

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