Only Significant OCIs Require Mitigation
Client Alert | less than 1 min read | 08.18.10
On August 5, 2010, the Federal Circuit in PAI Corp. v. U.S. affirmed the lower court's determination that contracting officers have an obligation to mitigate "significant" OCIs, but that the FAR does not require "mitigation of other types of conflicts, such as apparent or potential non-significant conflicts." The Federal Circuit also held that contracting officers have broad discretion to determine whether an OCI is "significant" and that FAR 9.504(a) does not require that contracting officers document their initial identification and evaluation of potential conflicts.
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Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies.
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Gaming Addiction Litigation: Turner v. Epic Games & Roblox and What It Means for the Industry
