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GSA Transactional Rule Pilot Program – Understanding the Seismic Shift

Client Alert | less than 1 min read | 08.29.16

The GSA’s Transactional Data Rule Pilot Program has been rolled out for certain schedules, but many questions remain for contractors, including the logistical challenges related to the monthly compilation of data, the ability of GSA contracting officers to compare products and services accurately as the agency moves from commercial pricing to horizontal pricing analysis, and the areas of potential liability under this new program. This article by C&M attorneys, published in Bloomberg BNA, provides a detailed explanation of the new rule and practical considerations for government contractors.

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Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....