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Potential OCI Short-Circuits Sole-Source Award

Client Alert | less than 1 min read | 01.17.08

In Superlative Technologies, Inc. (Jan. 4, 2008, http://www.gao.gov/decisions/bidpro/310489.pdf), GAO held improper the cancellation of a solicitation by DOJ due to potential Procurement Integrity Act (PIA) and organizational conflict of interest unfair competitive advantage problems when DOJ turned around and awarded a sole-source contract for the same work to a contractor using as a subcontractor the company with the PIA/OCI problem. GAO recommended that DOJ reopen the competition and follow the procurement integrity and OCI regulations to determine the scope of the problem and whether any offerors should be disqualified or other corrective actions should be required.

Insights

Client Alert | 7 min read | 08.19.26

CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care

On August 13, 2026, the Centers for Medicare and Medicaid Services (CMS) published its final rule banning the use of federal funds — through Medicaid and the Children’s Health Insurance Program (CHIP) — to pay for gender-affirming care for children and youth. The final rule takes effect October 13, 2026 (“Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children”). While CMS finalized several key elements of its late-2025 proposed rule (Client Alert December 24, 2025), the proposed Medicare hospital Condition of Participation rule remains in proposed form....