DoD's Guerilla War on IR&D
Client Alert | 1 min read | 02.10.16
In a notice published in the Federal Register on February 8 that will almost certainly be unpopular with contractors and their customers, DoD asked for comments on its consideration of adding a requirement to the DFARS that would "require offerors to describe in detail the nature and value of prospective IR&D projects on which the offeror would rely to perform the resultant contract." As described in the notice, that information would be used by DoD to "evaluate proposals in a manner that would take into account that reliance by adjusting the total evaluated price to the Government, for evaluation purposes only, to include the value of related future IR&D projects," presumably by increasing the evaluated price of that offeror's proposal to include the full value of the IR&D project.
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Client Alert | 4 min read | 11.09.26
CMS Finalizes Its 2026 Organ Procurement Organization Rule
On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions:
Client Alert | 7 min read | 11.05.26
2026 State Attorney General Elections: What Businesses Should Expect
Client Alert | 3 min read | 11.05.26
Federal, State, and Local Regulators Sue Toast Over B2B Advertising and Subscriptions
Client Alert | 3 min read | 11.04.26
CMS Proposal Would Overhaul Eligibility Rules for ACA Exchanges
