A New Dawn or New Nightmare: Will Transactional Data Reporting Reduce, or Merely Shift, GSA Schedule Contractors' Compliance Burden?
Client Alert | 1 min read | 06.23.16
Despite competing concerns expressed by both contractors and the IG, on June 23, 2016, GSA published a final rule proceeding with a pilot program imposing substantial monthly transactional data reporting obligations on contractors but relieving them from the burden of both commercial sales practices data submissions and the monitoring of commercial sales to tracking customers, as well as from the threat of price readjustments and possible FCA liability under the Price Reduction clause. The pilot program will initially apply to new contracts (and existing contracts where contractors elect to participate) under select GSA Schedules accounting for approximately 43 percent of GSA Schedule purchases, including Schedule 70 (Information Technology) and 00CORP (Professional Services), and continue for at least one year as GSA evaluates its ability effectively to collect and use transactional data and price analysis to assure better pricing for GSA Schedule customers.
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Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
On August 13, 2026, the Centers for Medicare and Medicaid Services (CMS) published its final rule banning the use of federal funds — through Medicaid and the Children’s Health Insurance Program (CHIP) — to pay for gender-affirming care for children and youth. The final rule takes effect October 13, 2026 (“Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children”). While CMS finalized several key elements of its late-2025 proposed rule (Client Alert December 24, 2025), the proposed Medicare hospital Condition of Participation rule remains in proposed form.
Client Alert | 2 min read | 08.19.26
Client Alert | 7 min read | 08.17.26
Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule
Client Alert | 4 min read | 08.14.26
License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations


