Karen L. Manos is a partner resident in Gibson Dunn's Washington D.C. office and Co-Chair of the firm's Government and Commercial Contracts Practice Group. Ms. Manos graduated in the top two percent of her class at the U.S. Air Force Academy (B.S., distinguished graduate, 1981), and graduated first in her class from the Duke University School of Law (J.D., with highest honors, 1986), where she was a Note Editor for the Duke Law Journal. Ms. Manos has more than twenty-five years experience on a broad range of government contracts issues, including civil and criminal fraud investigations and litigation, complex claims preparation and litigation, bid protests, qui tam suits under the False Claims Act, defective pricing, cost allowability, the Cost Accounting Standards, and corporate compliance programs.
Ms. Manos enjoys a nationwide reputation for her expertise in government contract costs and pricing. In 2004, Legal Times named Ms. Manos one of the top 12 government contracts lawyers in the Washington, DC area. In 2009, she was nominated by her peers as one of the world's leading practitioners in the field of public procurement and listed in The International Who's Who of Public Procurement Lawyers, and was also named as a Top Lawyer for government contracts in Washingtonian Magazine. In 2010, Ms. Manos was selected as one of 10 Washington, DC Super Lawyers in government contracts. Additionally, each year since 2006, Ms. Manos has been selected as one of the leading Government Contracts lawyers in the nation by Chambers USA America's Leading Business Lawyers, and one of only three lawyers "spotlighted" in the category, Government Contracts: Cost Disputes. Chambers reported that: "She is regarded by commentators as 'an absolutely top-class costs lawyer.' She is highlighted as 'the expert's expert, with great knowledge and a great attitude.'" One peer remarked, "She is one of the most brilliant cost accounting lawyers I've met, and a great theoretician. She is a perfectionist, and she's very, very good at a very, very difficult area."
Ms. Manos is the author of a three-volume book, Government Contract Costs & Pricing (Thomson-West 2d ed. 2009), which is widely regarded as the definitive text in the area. In addition, Ms. Manos has authored more than forty articles on government contract law. Her publications have appeared in the ABA Public Contract Law Journal, the Catholic University Law Review, Federal Contracts Report, The Government Contractor, the Cost Pricing & Accounting Report, the Nash & Cibinic Report, the Government Contract Audit Report, the Iraq Reconstruction Report, and Purchasing Today. She has also been quoted in the Wall Street Journal and Washington Business Journal, among other publications.
Ms. Manos is a past Chair of the American Bar Association Section of Public Contract Law and Chair of the National Defense Industrial Association Procurement Division and currently serves as Editor-in-Chief of both the Public Contract Law Journal and the Government Contract Accounting, Cost & Pricing Report.
Professional Associations
· American Bar Association, Section of Public Contract Law: Chair (2009-2010), Chair-Elect (2008-2009), Vice-Chair (2007-2008), Secretary (2006-2007), Council Member (2003-2006), and Co-Chair of the Accounting, Cost & Pricing Committee (2000-2003).
· National Defense Industrial Association: Chair, Procurement Policy Committee (2009-2011), Vice-Chair, Procurement Policy Committee (2007-2009); Chair, Contract Finance Committee (2004-2006).
· National Contract Management Association: Fellow, Certified Professional Contract Manager, and past President of the San Francisco Bay Area Chapter.
· Public Contract Law Journal Editor-in-Chief
· Cost, Pricing & Accounting Report Editor-in-Chief
· The Government Contractor Advisory Board Member
· Federalist Society Member
· Martindale-Hubbell AV Peer Review Rated
Publications
Books
· Government Contract Costs & Pricing (Thomson - West 2d ed. 2009)
Articles
· "Special Allocations Under the Cost Accounting Standards," 6-5 Cost, Pricing & Accounting Report 59 (September 2011).
· "Know Your Cost Regulations: The Public Relations And Advertising Costs Principle (FAR 31.205-1)," 6-3 Cost, Pricing & Accounting Report 27 (May 2011)
· "Contractor Business System Audits: The Coming Train Wreck," 5-6 Cost, Pricing & Accounting Report 1 (Nov. 2010).
· "Complying With the New Mandatory Disclosure Rule," 4-1 Cost, Pricing & Accounting Report 1 (Jan. 2009).
· "Choice of Forum for Government Contract Disputes," 3-4 Cost, Pricing & Accounting Report 31 (July 2008).
· Does the APA Still Apply to Government Contractors?," 2-5 Costs, Pricing & Accounting Report 44 (Sep. 2007).
· "Defining Increased Costs in the Aggregate," 2-2 Costs, Pricing & Accounting Report 11 (March 2007).
· "COFC Reconsiders CAS 413 Ruling," 49-9 Government Contractor, 95 (March 2007).
· "Recovery of Interest Against the Government," 1-3 Costs, Pricing & Accounting Report 21 (Nov. 2006).
· "Estoppel Against The Government: What Does "Affirmative Misconduct" Have To Do With It?," 1-1 Costs, Pricing & Accounting Report 1 (July 2006).
· "Practitioner's Comment: Information Systems & Networks Corp.," Fed. Cir. Nos. 04-5151 & 5154, 48 Government Contractor 61 (2006).
· "Postscript: Independent Research and Development Costs," 20 Nash & Cibinic Report 2 (Jan. 2006).
· "Cherokee Nation: More Than Meets the Eye," 19 Nash & Cibinic Report 29 (June 2005).
· "Estimates in Level of Effort Contracts: Wrong Contract Type, Wrong Breach," 19 Nash & Cibinic Report 23 (May 2005).
· "Allowability of Legal Costs," 05-5 Briefing Papers (April 2005).
· "Defining Cost or Pricing Data," 47 Government Contractor 192 (2005).
· "Status of Contractors in Iraq: What Laws Apply?," Iraq Reconstruction Report (2004).
· "FAR 31.205-18, Independent Research and Development and Bid and Proposal Costs," 03-12 Briefing Papers (Nov. 2003).
· "Caveat Contractor: DCAA's New Audit Guidance on the Sarbanes-Oxley Act and Contractor Internal Controls," 80:19 Federal Contracts Report 543 (2003).
· "The Proposed Rule on Cost Accounting Standards Administration - 'There You Go Again,'" 45 Government Contractor 302 (2003).
· "DDP's Guidance Paper on Changes in Cost Accounting Practice," 44 Government Contractor 80 (2002).
· "Practitioner's Comment: General Dynamics Corp., ASBCA 49372," 44 Government Contractor 249 (2002).
· "The Federal Circuit's Decision in Boeing North American: Better, But Still Wrong," 44 Government Contractor 203 (2002).
· "The Non-Appropriated Funds Doctrine: What Do You Mean We Can't Sue Them?" 6:7 Government Contract Audit Report (2001).
· "A Critical Analysis of the FAR Council's New Rule on Labor Relations Costs and Costs Relating to Legal and Other Proceedings," 75:1 Federal Contracts Report (2001).
· "Heads We Win, Tails You Lose: The CAS Board's Remarkable New Proposal on Accounting for the Costs of PRB Plans," 42 Government Contractor 420 (2000).
· Co-Author, "Affirmative Action Plans & The "Equal Pay Initiative," 00-8 Briefing Papers (Aug. 2000).
· Co-Author, "Pretrial Motions Under the False Claims Act," 29 Public Contract Law Journal 693 (2000).
· Co-Author, "A Critical Analysis of the CAS Board's Proposed Rule on Changes to Cost Accounting Practices," 41 Government Contractor 402 (1999).
· "Government Claims to Surplus Pension Assets," 48 Catholic University Law Review 1139 (1999).
· "Post-Retirement Benefits: Much Ado About Funding," 4:5 Government Contract Audit Report (1999).
· "The Statute of Frauds in Cyberspace," Purchasing Today (1999).
· "Allowability of ESOP Interest Costs: DCAA's Misguided Audit Guidance, 98-6 Costs," Pricing & Accounting Report (1998).
· "Legal: To Involve or Not to Involve," Purchasing Today (1998).
· "Allowability of Executive Compensation Costs," 97-13 Briefing Papers (Dec. 1997).
· Co-Author, "Executive Compensation: A Critical Examination of the Proposed Contract Costs Act of 1997," 97-3 Costs, Pricing & Accounting Report (1997).
· "Novation Agreements in Corporate Restructuring: The Government's Contractual Stealth Weapon," 26 Public Contract Law Journal 339 (1997).
· Co-Author, "Special Allocations Under the Cost Accounting Standards," 96-10 Costs, Pricing & Accounting Report (1996).
· Co-Author, "Voluntary Accounting Changes Under CAS: A Windfall for the Government?" 25 Public Contract Law Journal 457 (1996).
· "Protecting Proprietary Information," 94-13 Briefing Papers (Dec. 1994).
· "The Antideficiency Act without an 'M' Account: Reasserting Constitutional Control," 23 Public Contract Law Journal 337 (1994).
· "Recovery of Environmental Costs: A Government Perspective," 92-8 Costs, Pricing & Accounting Report (1992).
· Co-Author, Within Cockpit Communications Patterns and Flight Crew Performance, NASA Technical Paper (1982), discussed in 16:11 Psychology Today 42 (1982).
Publications
The Contract Disputes Act Statute Of Limitations: Take Your Time, DOD, Article, Nov 1, 2011
Special Allocations Under the Cost Accounting Standards, Article, Sep 1, 2011
U.S. Department of Defense Issues Interim Rule to Require Withholding of Payments to Contractors with Deficient Business Systems, Client Alert, May 24, 2011
Know Your Cost Regulations: The Public Relations and Advertising Costs Principal (FAR 31.205-1), Article, May 1, 2011
New Law Imposes Excise Tax on U.S. Government Payments to Foreign Entities, Client Alert, Mar 30, 2011
U.S. Department of Defense Issues Revised Proposed Rule to Require Withholding of Payments to Contractors with Deficient Business Systems, Client Alert, Dec 7, 2010
Contractor Business Systems Audits: The Coming Train Wreck, Article, Nov 9, 2010
FAR Councils Issue Final Rule Creating Federal Awardee Performance and Integrity Information System (FAPIIS), Client Alert, Mar 24, 2010
Department of Defense Announces Defense Contract Provisions Prohibiting Contractors' Use of Arbitration Agreements for Certain Employee Disputes, Client Alert, Feb 24, 2010
Proposed Legislation Would Allow Foreign Contractors to Be Sued in U.S. Courts, Client Alert, Dec 21, 2009
New Regulations Are Likely on Organizational Conflicts of Interest, Client Alert, Dec 15, 2009
Federal Circuit Denies Petition for Rehearing En Banc in Geren v. Tecom, Inc. Upholding the "Very Little Likelihood of Success on the Merits" Standard for Recovering Costs of Defending a Private Employment Discrimination Suit, Client Alert, Oct 7, 2009
Labor Department Proposes Rules Requiring Government Contractors to Post Notice of Unionization Rights, Client Alert, Aug 10, 2009
Webcast Briefing: Impact of Obama Administration's Labor and Employment Policies on Government Contractors, Webcast, Jun 18, 2009
Karen Manos Testifies Before the Subcommittee on Government Management, Organization and Procurement , Article, Jun 16, 2009
President Obama Signs Law to Reform Pentagon Weapons Spending (P.L. 111-124), Client Alert, May 27, 2009
Contractor Business Ethics Compliance Program & Disclosure Requirements, Article, Apr 6, 2009
President Obama Directs Additional Restrictions on Spending of Recovery Act Funds and Lobbying Communications Concerning the Expenditure of Such Funds and Related Policies, Client Alert, Mar 26, 2009
Obama Administration Undertakes Review of Procurement Law, Client Alert, Mar 5, 2009
Proposed Legislation Amending False Claims Act, Client Alert, Feb 26, 2009
Three Executive Orders Signed Friday Increase Employment Requirements on Federal Contractors, Client Alert, Feb 2, 2009
Delay in Implementing Certain Aspects of the U.S.-Iraq SOFA against U.S. Contractors, Client Alert, Jan 5, 2009
Complying With The New Mandatory Disclosure Rule, Article, Jan 1, 2009
New Status of Forces Agreement Subjects Government Contractors to Iraqi Law, Client Alert, Dec 1, 2008
Choice of Forum for Government Contract Disputes, Article, Jul 1, 2008
ITAR Update: Technical Data Found on the Internet May Not Be Considered in the Public Domain, Client Alert, May 9, 2008
Does The APA Still Apply To Government Contractors?, Article, Sep 1, 2007
Cost & Pricing Issues, Article, Mar 30, 2007
Defining "Increased Costs in the Aggregate", Article, Mar 15, 2007
COFC Reconsiders CAS 413 Ruling, Article, Mar 7, 2007
Webcast Briefing - Oversight in Government Procurement: The New Congress and the Justice Department's Enforcement Agenda, Webcast, Feb 13, 2007
Rule Change Significantly Alters Civil Settlement Negotiation Environment; Permits Government to Use Civil Settlement Statements in Criminal Prosecutions, Client Alert, Feb 5, 2007
Congress Proposes Legislation to Criminalize War Profiteering, Client Alert, Jan 18, 2007
Recovery of Interest Against the Government, Article, Nov 1, 2006
Department of Justice Establishes New Task Force to Combat Fraud In Government Contracting, Client Alert, Oct 13, 2006
Department of Defense Proposed Rule Highlights Need for Effective Export Compliance Program, Client Alert, Aug 14, 2006
Estoppel Against The Government: What Does 'Affirmative Misconduct' Have To Do With It?, Article, Jul 18, 2006
Shareholder Taxes On Dividends Are Not Allowable Costs For Subchapter S Corporation, Federal Circuit Holds, Article, Feb 22, 2006
Cost and Pricing Issues - West Government Contracts Year in Review Conference, Article, Feb 1, 2006