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Antitrust Division Update Affirms Continued Efforts of Procurement Collusion Strike Force

Client Alert | 1 min read | 06.24.20

As part of its 2020 Update, the DOJ’s Antitrust Division highlighted the ongoing work of its Procurement Collusion Strike Force (PCSF), with Assistant Attorney General Makan Delrahim specifically noting the work of the PCSF in his personal remarks. Calling the response to the PCSF “overwhelmingly positive”, Delrahim underscored the Division’s priority of enforcing the criminal antitrust laws and stated that the PCSF will be a primary tool for investigating and prosecuting criminal antitrust violations related to the COVID-19 pandemic.

The Update also reiterated that the interagency partnership has been hard at work in the ten months since its launch, identifying and investigating potential antitrust crimes in public procurements. The Update noted that since its inception in November, the PCSF has conducted more than 30 in-person training presentations in 13 states and the District of Columbia, and its work has continued during the pandemic with PCSF attorneys leading over a dozen interactive virtual training programs for 2,000 criminal investigators, data scientists, and procurement officials from 500 federal, state, and local agencies.

Importantly, the Update reported that DOJ has secured additional funding for the PCSF to support its outreach efforts, as well as its investigations, indicating the Antitrust Division has both the interest and the resources to remain focused on these issues for the foreseeable future.

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....