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Expert Analysis

6 Steps To Compliance With DOD's Business Systems Rule

Law360, New York (April 11, 2012, 12:33 PM EDT) -- The recently implemented final version of the U.S. Department of Defense's business systems rule [77 Fed. Reg. 11,355] presents a range of compliance issues and risks for covered contractors and their business systems, yet fails to provide practical guidance about what contractors can do to prepare for the new requirements. Given that the rule allows the government to withhold up to 10 percent of contractor payments (including subcontractor costs) if it finds one or more "significant deficiencies" in a contractor's business systems, current and potential future covered contractors should take a proactive approach to ensuring that their business systems will withstand scrutiny....

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