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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 | 5 min read | 04.23.26

CMS Proposes New Payment Policy for IOPOs and HCLs

In keeping with ongoing efforts to intensify regulatory oversight of organ procurement organizations (OPOs) and curtail improper spending within federal health programs, the Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would, among other adjustments, align Medicare payment policies for non-renal organs to be consistent with those currently applicable to kidneys. If enacted as drafted, this latest rule could have a direct impact on the financial stability of OPOs and histocompatibility laboratories (HCL) at a time when such organizations face increasing pressure to meet CMS’s new outcome measures — or else face non-renewal or decertification later this year. ...