Hits And Misses In DOD IR&D Rule

Law360, New York (March 20, 2012, 4:25 PM EDT) -- Last March, the U.S. Department of Defense issued a proposed rule regarding the reporting requirements for independent research and development, which raised concerns about how the proposed change would tie recoverability of IR&D costs to new reporting and disclosure requirements.[1]

Recently, Defense Federal Acquisition Regulation Supplement 231.205-18(c) was finalized, with changes. See 77 Fed. Reg. 4632 (Jan. 30, 2012). This final rule is a mixed bag that got some things right, but also leaves some of the most serious issues unresolved.

First — three things that...
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