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FAR Council Finalizes Reporting Requirements for Executive Compensation and First-Tier Subcontract Awards

Client Alert | less than 1 min read | 07.26.12

On July 26, 2012, the FAR Council issued a final rule requiring certain contractors to report executive compensation, first-tier subcontract awards, and executive compensation information for first-tier subcontractors for public release on the USASpending website. While the final rule is very similar to the interim rule issued on July 8, 2010, there is a substantive change to the definition of first-tier subcontract, and the preamble to the final rule contains extensive commentary to guide the implementation of the rule, including discussion of the application of the public company exemption.

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....