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Bring Out Your Dead: GSA Instructs Agencies to Remove Null and Void FPSW

Client Alert | 1 min read | 06.27.17

On June 12, 2017, the General Services Administration issued a Class Deviation to remove the Fair Pay and Safe Workplaces Final Rule from the FAR after President Trump signed a joint resolution (P.L. 115-11) under the Congressional Review Act disapproving the final rule on March 27, 2017. Although most of the final rule’s requirements were put on hold in October when a U.S. District Court judge in Texas granted a preliminary injunction (discussion available here), paycheck transparency requirements at FAR clause 52.222-60 became effective on January 1, 2017. In this Class Deviation, GSA instructs agencies to not wait for formal rescission of the rule, but to take all necessary steps to comply with the joint resolution, including ensuring that new solicitations do not include FAR clause 52.222-60 and amending solicitations or modifying contracts to remove FAR clause 52.222-60 if included in either.

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Client Alert | 6 min read | 03.06.26

Tri-Agencies Release Fourth Mental Health Parity Report to Congress

On March 3, 2026, the Department of Labor (DOL), Department of Health and Human Services (HHS), and Department of the Treasury (TREAS) — collectively, the “Tri-Agencies” — published their fourth annual report to Congress on enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA). The 2025 Report demonstrates a shift in approach by the Tri-Agencies in its tone and content and suggests that federal regulators, and the DOL in particular, are not as active as they previously were in MHPAEA enforcement. However, federal enforcement remains ongoing, and state enforcement of mental health parity laws continues to grow. Plans and issuers must continue to maintain comprehensive compliance processes and documentation for MHPAEA compliance....

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