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GSA Makes BAA and TAA Non-Availability Exception Due to COVID-19 National Emergency, Applicable to GSA Schedule Orders

Client Alert | less than 1 min read | 04.10.20

On April 3, 2020, the General Services Administration (GSA) issued a class determination of non-availability under both the Buy American Act (BAA) and Trade Agreements Act (TAA) clauses, effective through July 1, 2020 and applicable to GSA Schedule orders, to address the immediate and urgent needs of GSA and other agencies to preserve lives in the face of the COVID-19 pandemic. The class determination currently applies to enumerated products (N95 masks, bleach, disinfectants, cleaners, and hand sanitizers), though GSA stated that it may need to update and add items to meet evolving government needs, and encouraged stakeholders to provide updated information on product availability.

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....