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OFCCP Issues "Internet Applicant" Definition

Client Alert | less than 1 min read | 10.10.05

The Office of Federal Contract Compliance Programs ("OFCCP") issued a final rule on October 7, 2005, clarifying the definition of an "applicant" in the context of internet recruitment and amending recordkeeping requirements regarding internet applications. This long-awaited clarification narrows the applicant definition previously utilized by the OFCCP, but will require many contractors to modify existing data collection and recordkeeping practices by February 6, 2006, so contractors should initiate a comprehensive review of their selection, applicant tracking, and record retention processes promptly to ensure compliance with this new rule.

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Client Alert | 4 min read | 04.23.26

Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule

In mid-April, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37), which would — if enacted — impose new disclosure obligations on pharmacy benefit managers (PBM) regulated under the Employee Retirement Income Security Act of 1974 (ERISA)....