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OHA Authority and Impact Expanded

Client Alert | 1 min read | 02.11.11

On February 2, 2011, the Small Business Administration issued a final rule amending its regulations, effective March 4, 2011, to expand and better define the authority of SBA's Office of Hearings and Appeals (OHA) by allowing for OHA review of all timely appeals of size determinations, whereas traditionally OHA would not review formal size determinations if the contract had been awarded and the issues ripe for review were contract specific, including joint venture issues and violations of the ostensible subcontractor and non-manufacturer rules. Additionally, OHA now has to issue decisions within 60 days of the close of a record, and if OHA affirms a size determination finding a protested concern to be other than small the contracting officer must terminate the contract or not exercise the next option.

Insights

Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....