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Conflict of Interest by Government Official

Client Alert | less than 1 min read | 11.23.15

In Satellite Tracking of People, LLC (Nov. 6, 2015), GAO sustained what it called a first-of-kind protest concerning a government program manager who had been recently employed by one of the competitors in the procurement. Because the CO had stated in writing prior to proposal submission that the program manager should recuse herself, yet never followed through to enforce the recusal, GAO concluded that a known conflict of interest concern had been left unresolved and, therefore, prejudice to the protester arising from this conflict must be presumed.


Insights

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....