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DoD's Own Cyber Monday Deal: Releasing DFARS Cyber Enhancement Guidance

Client Alert | 1 min read | 11.27.18

Just in time for the holidays, the Defense Department published final guidance to the DoD acquisition community that details strategies to enhance existing cybersecurity requirements for Covered Defense Information (CDI) provided by the DFARS Safeguarding Clause 252.204-7012. The DoD’s guidance contains two documents that clarify how DoD will communicate their cybersecurity expectations to contractors, including where those expectations exceed what the DFARS Safeguarding Clause requires:

  • Guidance for Reviewing System Security Plans (SSPs) outlines how the DoD expects to evaluate contractor SSPs, including the preferred method of meeting each NIST security control and the anticipated consequences of not yet having implemented those controls.
  • Guidance for Assessing Compliance and Enhancing Protections provides objectives that requiring activities can tailor to assess contractors’ safeguarding of CDI, including how to incorporate compliance with NIST SP 800-171 and supply chain management as evaluation criteria in solicitations.

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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....