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GSA Seeks Comments on Proposed Class Deviation to Address Open "Recurrent Points of Inconsistency" in Commercial Supplier Agreements

Client Alert | 1 min read | 03.20.15

On March 20, 2015, the General Services Administration published a notice seeking comments on a proposed class deviation to the Federal Acquisition Regulation and General Services Acquisition Regulation intended to address "recurrent points of inconsistency" between Federal law and commercial supplier agreements, to establish that the FAR's commercial item terms take precedence over commercial supplier agreements, and to implement standard terms and conditions in order to minimize the need to individually negotiate agreements. GSA has provided a roadmap to all the terms and conditions customarily used by contractors in commercial supplier agreements (15 in total) that it believes conflict with Federal law; contractors have an opportunity to submit comments on this proposed class deviation on or before April 20, 2015.

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Client Alert | 4 min read | 08.29.25

Gender-Affirming Care Targeted for Potential False Claims Act Enforcement

On August 19, 2025, the Office of Personnel Management (OPM) informed insurers participating in the Federal Employees Health Benefits or Postal Service Health Benefits programs that gender-affirming care would no longer be covered for federal workers starting in 2026. This coverage decision is the Trump Administration’s latest action stemming from Executive Order 14187 which aims to prevent certain treatments, such as gender-affirming hormone therapy, surgeries, and puberty blockers for those under the age of 19. As previously discussed, the Administration has also signaled its intent to use various law enforcement tools against gender-affirming care, including  Section 5 of the Federal Trade Commission Act to police false or unsupported claims by medical professionals about gender-affirming treatments....