DoD's Proposed Counterfeit Electronic Parts Rules Are Short on Details
Client Alert | 1 min read | 05.22.13
Following up on its publication of an instruction on counterfeit parts on May 16, DoD issued a long-expected proposed rule on counterfeit electronic parts avoidance, detection, and liability, with comments due by July 15. As discussed on our blog, the rule -- which applies only to CAS-covered prime contractors but will have a much broader impact on subcontractors and suppliers -- requires that business systems include DoD-approved avoidance and detection systems, but leaves the details of the newly required systems to be fleshed out, it would seem, by DCAA and/or DCMA, and, while it imposes potentially unlimited liability for counterfeit parts, it has an exceedingly narrow "safe harbor."
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Client Alert | 3 min read | 11.04.26
CMS Proposal Would Overhaul Eligibility Rules for ACA Exchanges
The Centers for Medicare and Medicaid Services (CMS) is proposing significant changes to the way Affordable Care Act (ACA) health insurance exchanges verify consumer eligibility before federal subsidies are made available.
Client Alert | 7 min read | 11.04.26
FDA Issues Guidance on Prescription Drug Use-Related Software
Client Alert | 7 min read | 11.02.26
Client Alert | 4 min read | 10.30.26
