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DCAA "Independence"

Client Alert | 1 min read | 03.24.09

The Defense Contract Audit Agency (DCAA) has revised its policy concerning "unsatisfactory conditions related to actions of Government Officials" to provide that "significant and serious" disagreements with actions by government officials, including contracting officers, will be reported directly to the Inspector General rather than to the Government official's management chain, as had been the policy in the past (Mar. 13, 2009). Prior guidance had already required direct reporting of "suspected irregularities" such as criminal violations, and this guidance appears to be intended to cover discretionary decisions that the auditors believe will "result in substantial harm to the Government or taxpayers, or that frustrate public policy."

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....