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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 | 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....