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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 | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....