New Post-Employment "Revolving Door" Certification
Client Alert | 1 min read | 11.18.11
On November 18, 2011, in the wake of high-profile enforcement actions and bid protests demonstrating the risks involved when contractors recruit and hire former government personnel (e.g., Health Net Fed. Servs.), the DoD issued a final rule that, for the first time, will require offerors to certify that “all covered DoD officials employed by or otherwise receiving compensation from the offeror, and who are expected to undertake activities on behalf of the offeror for any resulting contract, are presently in compliance with all post-employment restrictions covered by 18 U.S.C. 207, 41 U.S.C. 2101-2107, and 5 CFR parts 2637 and 2641, including Federal Acquisition Regulation 3.104-2.” This new requirement further reinforces the necessity for contractors to have robust internal systems to identify and monitor in a timely way the post-employment restrictions imposed on their employees and consultants who are former government personnel.
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Client Alert | 4 min read | 11.10.26
D.C. District Court Upholds CMS’s 2020 Organ Procurement Rule
It’s been about a month since the U.S. District Court for the Middle District of Florida upheld the Centers for Medicare and Medicaid’s (CMS) final rule governing organ procurement organizations (OPM). (See our previous Client Alert here.) The U.S. District Court for the District of Columbia followed suit. In contrast to the Florida decision, the D.C. decision was brief and to the point. The rule establishes a competitive model for classifying OPOs under the following three tiers.
Client Alert | 8 min read | 11.10.26
EU Simplifies Rules on Defense Procurement and Transfers of Defense-Related Products
Client Alert | 3 min read | 11.09.26
Client Alert | 4 min read | 11.09.26
