Offerors Now Must Disclose Information about Owners, Subsidiaries, and Predecessors
Client Alert | less than 1 min read | 03.09.16
On March 7, 2016, the FAR Council issued a final rule that requires offerors to disclose within the Federal Awardee Performance and Integrity Information System any immediate owner or subsidiary and all predecessors of an offeror that held a federal contract or grant within the last three years. The final rule is designed to provide COs with a “more comprehensive understanding of the performance and integrity of the corporation before awarding a Federal contract . . .,” and it may also affect how contractors draft their proposals to explain their corporate family trees.
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Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
Client Alert | 4 min read | 04.16.26
ROI Tracking as Mens Rea? Novartis Ruling Reframes AKS Pleading Risk
