It’s Time for a Raise! DoD Proposes to Increase CPSR Threshold
Client Alert | 1 min read | 06.11.19
On May 31, 2019, DoD issued a proposed rule, which would amend the Defense Acquisition Regulation Supplement (DFARS) to establish a DoD-specific Contractor Purchasing System Review (CPSR) threshold of $50M at DFARS 244.302, to be used in lieu of $25M threshold at FAR 44.302(a), which has remained unchanged since 1996. According to the Federal Register, it is estimated that, with this new threshold in place, DCMA ACOs can reduce the number of contractor reviews by approximately 20% (from around 667 to 534), which would reduce the burden on smaller contractors and allow a more efficient and effective use of CPSR resources to review larger contractors where more taxpayer dollars are at risk. Comments on the rule are due by July 30, 2019.
Contacts
Insights
Client Alert | 6 min read | 03.06.26
Tri-Agencies Release Fourth Mental Health Parity Report to Congress
On March 3, 2026, the Department of Labor (DOL), Department of Health and Human Services (HHS), and Department of the Treasury (TREAS) — collectively, the “Tri-Agencies” — published their fourth annual report to Congress on enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA). The 2025 Report demonstrates a shift in approach by the Tri-Agencies in its tone and content and suggests that federal regulators, and the DOL in particular, are not as active as they previously were in MHPAEA enforcement. However, federal enforcement remains ongoing, and state enforcement of mental health parity laws continues to grow. Plans and issuers must continue to maintain comprehensive compliance processes and documentation for MHPAEA compliance.
Client Alert | 4 min read | 03.05.26
Client Alert | 8 min read | 03.05.26
Client Alert | 4 min read | 03.04.26
Sixth Circuit Finds EFAA Arbitration Bar to Entire Case — Not Just Sexual Harassment Claims

