OCI Mitigation Doesn't Go Far Enough
Client Alert | 1 min read | 02.13.06
In Greenleaf Constr. Co. (Jan. 17, 2006, http://www.gao.gov/decisions/bidpro/29310518.pdf), GAO found an unmitigated organizational conflict of interest because the owner of the awardee was to receive a stream of payments from another contractor that the awardee would be overseeing and evaluating and whose economic well-being the awardee therefore could significantly affect. The owner of the awardee had been required by the agency to sell the other contractor in order to avoid having an OCI interest in the profits of that other contractor, but GAO found that the interest of the awardee's owner in ensuring that the other contractor would be able to continue making the payments to him might impair the awardee's objectivity in performing its contract evaluation duties.
Insights
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
On August 13, 2026, the Centers for Medicare and Medicaid Services (CMS) published its final rule banning the use of federal funds — through Medicaid and the Children’s Health Insurance Program (CHIP) — to pay for gender-affirming care for children and youth. The final rule takes effect October 13, 2026 (“Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children”). While CMS finalized several key elements of its late-2025 proposed rule (Client Alert December 24, 2025), the proposed Medicare hospital Condition of Participation rule remains in proposed form.
Client Alert | 2 min read | 08.19.26
Client Alert | 7 min read | 08.17.26
Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule
Client Alert | 4 min read | 08.14.26
License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations
