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Making a List, Checking it Twice: OIG Report Details Contractor Payments Under Section 3610 of the CARES Act

Client Alert | less than 1 min read | 12.16.20

On December 9, 2020, the Department of Defense Office of Inspector General (DoD OIG) released its Audit of Department of Defense Implementation of Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act. The audit report assesses several aspects of how the DoD has issued relief under Section 3610, including how well contracting officers have complied with guidance, issues with contractor disclosures, and common reasons for denying relief. For an in-depth summary of the report, read the full article here.

Insights

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. ...