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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 | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....