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Pass-Through Cost Proposed Rule

Client Alert | less than 1 min read | 07.11.14

The government issued on July 10, 2014, a proposed rule that would require all agencies to justify contract awards, except those to small businesses, that propose to pass through more than 70 percent of the total cost of work to subcontractors by considering the availability of alternative contract vehicles and the feasibility of contracting directly with the proposed subcontractor(s) and to make a written determination that the selected contracting approach is in the best interest of the government. Written comments on the proposed rule are due September 9, 2014.


Insights

Client Alert | 4 min read | 11.10.26

D.C. District Court Upholds CMS’s 2020 Organ Procurement Rule

It’s been about a month since the U.S. District Court for the Middle District of Florida upheld the Centers for Medicare and Medicaid’s (CMS) final rule governing organ procurement organizations (OPM). (See our previous Client Alert here.) The U.S. District Court for the District of Columbia followed suit. In contrast to the Florida decision, the D.C. decision was brief and to the point. The rule establishes a competitive model for classifying OPOs under the following three tiers. ...