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Changes to Acquisition Thresholds On the Way

Client Alert | less than 1 min read | 07.29.15

On July 2, 2015, the FAR Council published a final rule, effective October 1, 2015, increasing the micro-purchase base threshold to $3,500 (from $3,000), that for use of simplified acquisition procedures for acquisition of commercial items to $7 million (from $6.5 million), the cost or pricing data threshold and the Cost Accounting Standard threshold to $750,000 (from $700,000), the prime contractor subcontracting plan floor to $700,000 (from $650,000), and the threshold for reporting first-tier subcontract information (including executive compensation) to $30,000 (from $25,000). The simplified acquisition threshold ($150,000) and the construction threshold ($1.5 million) will remain at current levels.


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Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....