Mr. Bouquet’s work in the field of government contracts has involved many types of products and services in a wide range of industries.
Reflections on Government Contracts
Federal Acquisition Regulatory Council Finalizes New Rules Regarding Employment of Veterans
On May 7, 2015, the Federal Acquisition Regulatory Council finalized changes to the Federal Acquisition Regulation (“FAR”) that implement new Department of Labor (“DOL”) rules regarding federal contractors’ employment of veterans. The major changes in the new rules involve: a new requirement to set benchmarks for hiring of veterans; changes to affirmative action program content; amendments of rules relating to job listings; expanded DOL access to contractor records of compliance; and requirements for pre-award compliance evaluations.
Defense Contract Audit Agency (“DCAA”) Issues Audit Guidance on Identification of Expressly Unallowable Costs
On January 7, 2015, the DCAA issued an audit alert (the “Alert”) supplementing previously issued guidance to auditors regarding how to identify expressly unallowable costs for purposes of assessing certain administrative penalties under cost reimbursement type government contracts. The Alert states that in order for a cost to be expressly unallowable, the Government must show that it was unreasonable under all the circumstances for a person in the contractor’s position to conclude that the costs were allowable. In particular, auditors must conclude that a cost is expressly unallowable if the FAR: (1) states in direct terms that the costs are unallowable, or leaves little room for differences of opinion as to whether the particular cost meets the allowability criteria; or (2) identifies the specific cost or type of costs in a way that leaves little room for interpretation.
Contractors Continue to Confront Challenges of New Department of Defense (“DoD”) Rule Concerning Detection and Avoidance of Counterfeit Electronic Parts
Contractors are continuing to confront challenges associated with a final rule issued by DoD in 2014 that imposes significant new anti-counterfeiting requirements on the DoD supply chain for electronic parts.
Chris Bouquet is an experienced businessman and government contracts lawyer. After college, he spent 11 years as a businessman, first serving as Assistant to the President of a company in Salem, Virginia and later as a Project Manager and Director of Government Operations for a government contractor in McLean, Virginia. While serving as a government contractor, he attended night school and received MBA and JD degrees. After law school, he served for nearly 14 years as a government contracts lawyer in McKenna Long & Aldridge's (MLA’s) Washington, DC office and as a pro bono lawyer for the Washington Legal Clinic for the Homeless. In 2008, he opened his own law practice in Alexandria, Virginia, so that he could be closer to home, church and community and offer existing and new clients more cost effective access to his expertise. Throughout Mr. Bouquet’s career, he has been devoted to understanding his clients’ needs and providing leadership to develop and implement effective strategies to meet these needs.