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NAFI Contractor Goes Straight to Court When CO Fails to Issue Final Decision

Client Alert | less than 1 min read | 01.24.12

In SUFI Network Servs., Inc, v. U.S. (Jan.17, 2012), the Court of Federal Claims denied the government’s motion to dismiss for lack of jurisdiction, relying on the Federal Circuit’s decision in Slattery v. U.S., 635 F.2d 1298, 1321 (Fed. Cir. 2011) (en banc), that the court has Tucker Act jurisdiction over all NAFI disputes. The court also found, in this non-CDA matter, that the CO had materially breached the contract’s Disputes clause by failing to provide a final decision on SUFI’s claim within a reasonable time, excusing SUFI from going to the board first, as the clause specified.

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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. ...