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OCIs Down Air Force Award

Client Alert | less than 1 min read | 09.14.09

In L-3 Servs., Inc. (Sept. 3, 2009) the GAO found unreasonable the Air Force's conclusions that the awardee did not have either a "biased ground rules" or "unequal access to information" OCI when the awardee's subcontractor had performed procurement planning services that put it in a position to affect the subsequent competition and that gave the subcontract access to non-public information that potentially conferred an unfair competitive advantage in that subsequent competition. The Air Force had initially gotten it right, determining that the subcontractor was barred from participating in the subsequent procurement, only to reverse that decision, thereby setting the stage for GAO's decision sustaining the protest.

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. ...