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Awards Reinstated After Faulty 'Corrective Action'

Client Alert | less than 1 min read | 04.11.14

In WHR Group, Inc. v. U.S. (Apr. 8, 2008), the Court of Federal Claims set aside an agency's "corrective action" terminating three blanket purchase agreements for employee relocation services because that action was not narrowly tailored to address the flaw in the underlying procurement. While the agency cited a laundry list of reasons for why it believed termination and reprocurement was necessary, Judge Block rejected nearly all of them and, as to the one issue that legitimately raised a concern about the prior evaluation, he concluded that a reevaluation would address the problem without a full resolicitation.

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Client Alert | 7 min read | 11.02.26

DOL Finalizes PBM Fee Disclosure Requirements

On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time. ...