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Last Chance to Comment on FASC Rule – More Supply Chain Restrictions Coming

Client Alert | 1 min read | 10.28.20

Companies have less than one week to submit comments regarding a recent interim rule that provides the responsibilities, processes, and procedures for the Federal Acquisition Security Council (FASC), established by the Federal Acquisition Supply Chain Security Act of 2018.  Under the immediately effective interim rule, the FASC is responsible for assessing supply chain risk and making removal and exclusion recommendations to the Secretary of the Department of Homeland Security (DHS), Secretary of the Department of Defense (DoD), and Director of National Intelligence (DNI).  Based on these recommendations, DoD, DHS, and the Office of the DNI (ODNI) then have authority to issue exclusion and removal orders for sources and/or covered articles deemed to pose a supply chain risk from certain procurements.

Click here to read this blog post on Government Contracts Legal Forum.

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Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....