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Department of Labor Institutes New Pilot Program to Expedite Processing of Discretionary Suspensions and Debarments

Client Alert | 1 min read | 04.04.19

On April 2, the Department of Labor (DOL) announced a new pilot program for discretionary suspensions and debarments in an effort to decrease DOL’s processing time of these actions “from months to days.” As part of the program, DOL’s Office of Inspector General (OIG) will include in its referrals to the Office of the Assistant Secretary for Administration and Management (OASAM) information based on indictments or convictions, with the hope that such information will allow OASAM to process these actions more quickly. Because of the unique nature of DOL debarments – which are largely imposed as a collateral consequence of labor violations – the pilot program increases risk to government contractors under scrutiny by DOL and its components/programs. This development emphasizes the importance of hiring counsel with capabilities to address the full spectrum of risks, including a proactive approach to suspension and debarment defense. 

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....