Mandatory Suspension/Debarment Review For "Poorly Performing" Contractors
Client Alert | 1 min read | 03.23.10
In another sign that the government is increasing its focus on suspension and debarment, a February 2010 Department of Homeland Security IG report found that DHS has been reluctant to apply existing procedures against poorly performing contractors and recommended that DHS develop policies to determine whether to refer them to the suspension and debarment official when their contracts have been terminated for default or are being considered for default. DHS management concurred with the recommendation and will now require that contracting officers provide any determination of nonresponsibility to the S/D official when the determination is based in whole or part on the contractor's (1) lack of satisfactory performance record under DHS contracts; (2) lack of satisfactory record of integrity and business ethics; or (3) inability to qualify or ineligibility under applicable laws and regulations.
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.
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
