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Expressly Unallowable Costs: DCAA's (Latest) Blunderbuss Attack

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The Defense Contracting Audit Agency‘s (“DCAA’s”)  focus on squeezing every penny from contracts has reached a new level with two recent memoranda to auditors providing guidance on identifying allegedly “expressly unallowable costs.”  As discussed below, in many respects the guidance seems inconsistent with both the language and intent of the applicable statutes and regulations.

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