DoD Publishes New Other Transactions Guidance
Client Alert | 1 min read | 12.07.18
DoD recently published a new online Other Transactions (OT) Guide, replacing the Other Transactions Guide for Prototype Projects, Version 1.2, dated January 2017. Whereas the previous guide applied only to prototype OTs, the new OT Guide addresses research other transaction agreements (OTAs) under 10 U.S.C. §2371, prototype OTAs under 10 U.S.C. §2371b, and follow-on production OTAs under 10 U.S.C. §2371b(f). The new OT Guide also provides practical guidance to Government Agreement Officers and attempts to debunk “Common OT myths.” Among other things, the new OT Guide reinforces that OTAs are intended to be flexible instruments, for example, by encouraging Agreements Officers to negotiate intellectual property rights that differ from those that would apply to FAR-based procurement contracts.
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Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
On August 13, 2026, the Centers for Medicare and Medicaid Services (CMS) published its final rule banning the use of federal funds — through Medicaid and the Children’s Health Insurance Program (CHIP) — to pay for gender-affirming care for children and youth. The final rule takes effect October 13, 2026 (“Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children”). While CMS finalized several key elements of its late-2025 proposed rule (Client Alert December 24, 2025), the proposed Medicare hospital Condition of Participation rule remains in proposed form.
Client Alert | 2 min read | 08.19.26
Client Alert | 7 min read | 08.17.26
Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule
Client Alert | 4 min read | 08.14.26
License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations



