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Federal Circuit Holds New Task Order Contract Awards Can Be Protested Without Full Procurement

Client Alert | 1 min read | 07.14.16

In Coast Professional, Inc. v. U.S. (July 12, 2016), the Federal Circuit revived bid protests (including that of the lead appellant, represented by Crowell & Moring) challenging task order contract awards that had previously been dismissed for lack of jurisdiction by the CFC. The court held that, because the appellants were challenging the “proposed award or the award” of new task orders under GSA Federal Supply Schedule contracts, which challenges fall squarely within the CFC’s statutory bid protest jurisdiction, it was irrelevant whether the new task orders, which were in the form of award-term extensions, shared some functional similarities to options or originated out of existing contracts rather than being the subject of entirely separate procurements.

Insights

Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....