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GAO Rejects Cooperative Agreements Dodge

Client Alert | less than 1 min read | 08.27.12

On August 15, 2012, GAO sustained a protest by several housing agencies challenging HUD's attempt to obtain services through cooperative agreements, finding that HUD improperly avoided the procurement laws and should have awarded a contract. GAO's ruling serves as a reminder that agencies cannot avoid CICA requirements by using cooperative agreements (or inter/intra-agency agreements, which have also received recent attention for possible abuse) to avoid the competitive procurement laws.

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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)....