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FAPIIS Information To Be Publicly Available

Client Alert | less than 1 min read | 08.03.10

On July 29, 2010, President Obama signed the supplemental appropriations bill which contained a provision amending the Clean Contracting Act of 2008 -- the legislation that gave rise to the Federal Awardee Performance and Integrity Information System ("FAPIIS"). As a result of the new language ("the Administrator shall post all such information, excluding past performance reviews, on a publicly available Internet website"), information in FAPIIS must be made available to the public, except for past performance reviews.

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Client Alert | 7 min read | 11.02.26

DOL Finalizes PBM Fee Disclosure Requirements

On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time. ...