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Disharmony in the Cyber Acquisition Patchwork

Client Alert | 1 min read | 05.07.15

While Executive Order No. 13636 asked for a review of "what steps can be taken to harmonize" existing cyber regulations governing federal acquisitions, a patchwork of more than a dozen different agency regulations – and dozens upon dozens of unpublished cyber policies – impose heavy burdens upon contractors seeking to build cost-effective cybersecurity compliance programs. On May 11, C&M's David Z. Bodenheimer will discuss this analysis and lead a co-sponsored program for the ABA Public Contract Law Section's Cybersecurity, Privacy, and Information Security Committee and the Science & Technology Law Section's Homeland Security Committee on "The Cybersecurity Patchwork of Federal Agency Rules & Unpublished Policies: How Do Contractors Comply?"

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....