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Expanding FAPIIS: First "Ownership," Now "Predecessors"

Client Alert | less than 1 min read | 12.17.14

On December 4, 2014, the FAR Councils issued a proposed rule that would require offerors to disclose all "predecessor" entities that held a federal contract or grant within the prior three years, with comments due by February 2, 2015. This information, in addition to the recent addition of ownership information, will be stored in the Federal Awardee Performance and Integrity Information System (FAPIIS).


Insights

Client Alert | 4 min read | 04.23.26

Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule

In mid-April, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37), which would — if enacted — impose new disclosure obligations on pharmacy benefit managers (PBM) regulated under the Employee Retirement Income Security Act of 1974 (ERISA)....