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OMB Releases Final Federal Source Code Policy

Client Alert | 1 min read | 08.12.16

On August 8, 2016, OMB released the final federal source code policy, which requires new, custom-made source code developed specifically by or for the federal government to be made available for sharing and reuse across all federal agencies in an effort to minimize duplicative procurements and reduce federal vendor lock-in. The policy also establishes a pilot program that requires agencies commissioning new, custom software to release at least 20 percent of that code as open source software (OSS) for three years, which will require agencies to consider the value of publishing custom code as OSS and negotiate data rights reflective of its value, as well as to obtain sufficient rights to fulfill the policy’s objectives.


Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....