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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 | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....