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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.


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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....