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FAR Amended to Standardize Past Performance Evaluations

Client Alert | less than 1 min read | 08.05.13

On August 1, 2013, the FAR was amended to provide for standardized past performance evaluation factors and performance rating categories for use government-wide and to require that past performance information be entered into the Contractor Performance Assessment Reporting System (CPARS). The final rule, which becomes effective on September 3, 2013, leaves intact the existing process to appeal an evaluation and places an emphasis on monitoring the quality and timeliness of submission of past performance information.


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Client Alert | 4 min read | 04.23.26

Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule

In mid-April, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37), which would — if enacted — impose new disclosure obligations on pharmacy benefit managers (PBM) regulated under the Employee Retirement Income Security Act of 1974 (ERISA)....