IG Report Whacks DCMA's Oversight of Contractors' Business Systems
Client Alert | less than 1 min read | 10.13.15
On October 1, the DoD IG released a report entitled, "Evaluation of Defense Contract Management Agency Actions on Reported DoD Contractor Business System Deficiencies," asserting that DCMA contracting officers "repeatedly" failed to comply with DFARS requirements involving reported business system deficiencies. The report, which is similar to one issued on June 29 regarding DCMA's treatment of estimating system deficiencies (available here), focused its criticisms on DCMA, despite DCMA's comments noting that DCAA, rather than DCMA, is responsible for determining whether a "significant" business system deficiency exists.
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Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
