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DOD Issues Final OCI Rule For Major Programs

Client Alert | 1 min read | 12.30.10

In its much anticipated final OCI rule, issued December 29, 2010, DOD limited the new provisions to changes required by the Weapons Systems Acquisition Reform Act of 2009 for major defense acquisition programs ("MDAPs") and pre-MDAP programs, in contrast to the proposed rule, which would have been applicable to all DOD acquisitions. Additional key changes from the proposed rule include: (i) making clear that this final rule takes precedence over FAR subpart 9.5, to the extent that there are inconsistencies; (ii) adding an explanation of the basic goals to promote competition and preserve DOD access to the expertise of qualified contractors; (iii) removing the formal preference for mitigation as the preferred resolution strategy; (iv) tightening the System Engineering and Technical Assistance ("SETA") contractor exception for domain experience and expertise to require a head of the contracting activity determination; and (v) refining definitions of major subcontractor and systems engineering and technical assistance.

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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....