DOL Again Applies Expansive Interpretation of "Subcontractor"
Client Alert | less than 1 min read | 10.29.10
In Office of Fed. Contract Compliance Programs v. Fla. Hosp. of Orlando (Oct. 28, 2010), a DOL Administrative Law Judge determined that a hospital providing medical services pursuant to an agreement with a TRICARE-managed care support contractor was a government subcontractor for purposes of a DOL audit of the hospital's compliance with its affirmative action and non-discrimination obligations. As discussed further in our blog, the ALJ analogized the hospital's status in this case to the hospital that provided medical services pursuant to an agreement with an FEHBP contractor in the UPMC Braddock case last year, which is currently under appeal.
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Client Alert | 5 min read | 04.13.26
EU Pharma Package: Global (Orphan) Marketing Authorization Compromise Proposal
In our fifth alert in this EU Pharma Package Series, we provided an analysis of the background and ongoing legal debates regarding the concept of the global marketing authorization (GMA). We discussed in particular the missed opportunities in the Pharma Package to further codify and clarify the GMA, in view of its central role in determining the regulatory data protection (RDP) rights of a medicinal product.
Client Alert | 4 min read | 04.13.26
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Client Alert | 2 min read | 04.10.26
