GSA Finally Confirms that Contractors Can Opt Out of Transactional Data Reporting
Client Alert | 1 min read | 08.18.17
On Thursday, the General Services Administration formally announced that starting with the new solicitation refresh (anticipated in October 2017), participation in the Transactional Data Reporting pilot will be voluntary. Significantly, GSA has also announced that contractors that were forced into TDR (for new contract awards, option exercises, or the addition of a TDR-covered SIN) will have a one-time opportunity to opt back out of TDR. While the long-term fate of the TDR approach to pricing (which replaces the requirement for Commercial Sales Practices disclosures and Basis of Award customer tracking) remains uncertain, this announcement suggests that these long-standing approaches will not be completely eliminated any time soon.
Contacts
Insights
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).
Client Alert | 5 min read | 04.23.26
Client Alert | 3 min read | 04.23.26
Crowell Tracker of Court Rulings on Legal Privilege and Artificial Intelligence Tools
Client Alert | 2 min read | 04.23.26
Two Lawsuits in One: The Growing Risk of Pairing Biometric Tech With Wage-and-Hour Violations
