Helping Us Help You: DDTC Modernizes ITAR Exemption for Contractor’s Supporting Government Agencies
Client Alert | 1 min read | 04.22.19
On April 19, 2019, nearly four years after the initial proposal, DDTC issued a final rule modifying § 126.4 of the International Traffic in Arms (ITAR) to clarify and expand the exemption authorizing exports in support of the US Government, including US foreign assistance and cooperative programs. Most significantly, the revised exemption acknowledges the government’s expanded use of contractor personnel in supporting USG missions often involving foreign parties. The exemption now expressly covers defense services and other exports by “persons or entities in a contractual relationship with the U.S. Government” where use of the defense article or performance of the defense service is within the scope of such contract and where any one of three specified conditions exist and assure government control and oversight of the transfer.
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Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
