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DPAS Regs Updated and Expanded

Client Alert | less than 1 min read | 08.15.14

On August 14, 2014, Commerce's Bureau of Industry and Security issued a final rule revising the Defense Priorities and Allocations System (DPAS) Regulations. Among other changes, the final rule (1) expands the scope of DPAS coverage by adding homeland security and critical infrastructure protection/restoration activities as reasons that rated orders may be issued; (2) adds language clarifying that recipients of rated orders have delegated authority to place ratings on contracts or orders with lower-tier contractors, subcontractors, and suppliers; and (3) reduces the time for written follow-up if a party is unable to comply with a rated order. 

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....