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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 | 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)....