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A-76 Mix And Match Faulted By GAO

Client Alert | less than 1 min read | 08.16.04

In Career Quest (Aug. 2, 2004), GAO sustained a protest of the GSA's decision under OMB Circular A-76 that it was more economical to continue performance of services in-house at the National Customer Support Center, as the agency evaluated the in-house offeror's technical performance plan based on a higher level of staffing than the same offeror included in its cost of performance. Inconsistencies between in-house offerors' staffing levels for compliance with work requirements and those it uses for calculating the cost of performance remain a persistent problem in A-76 competitions, and this decision sends the message that GAO will be alert to such shell games.

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Client Alert | 3 min read | 01.21.26

Atlantic Biologicals Opioid DPA: DOJ Continues Ramp Up of Criminal Corporate Healthcare Enforcement

On January 13, 2026, Miami-based pharmaceutical wholesaler Atlantic Biologicals Corporation entered into a two-year DPA, admitting to conspiracy to distribute and dispense controlled substances, including more than 14 million opioid doses to “pill mill” pharmacies in Texas at a markup. The DOJ and DEA underscored the company’s deliberate evasion of compliance checks and disregard for red flags signaling diversion....