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Contractor Gets "Second Bite" When Final Decision Reconsidered

Client Alert | less than 1 min read | 08.03.15

In LRV Envtl., Inc. (July 14, 2015), the ASBCA found that "reconsideration" of a CO's final decision resets the 90-day clock for a CDA appeal. The CO had issued a final decision, but subsequently reconsidered a portion of it on its own motion, leading the board to conclude that "the decision was not truly final" prior to the reconsideration and so the contractor's 90-day appeal window ran from the latter decision.


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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. ...