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Proposed NRO Clause Would Require Broad Disclosure -- Comments Due Tomorrow

Client Alert | 1 min read | 02.12.04

The proposal of the National Reconnaissance Office (NRO) to add a new standard clause to its contracts that would provide that "contractors and their employees, agents, representatives, subcontractors, and employees of subcontractors shall report to the NRO Inspector General (IG) or General Counsel any and all possible violations of federal criminal law or illegal intelligence activities of which they become aware during performance under an NRO contract," make all relevant records and employees available to the IG (failure to do so grounds for default termination), and flow the clause down to subcontractors raises obvious and serious policy issues. The request for comments are due tomorrow, February 13, despite only being published on February 4, on the NRO website, where the full text of the proposed clause is available.

Insights

Client Alert | 7 min read | 06.26.26

Federal Roundup: Updates for PBMs and Medicare Advantage Organizations

In June 2026, federal regulators and lawmakers continued their efforts to improve drug affordability through targeted reforms. These recent developments will primarily impact pharmaceutical manufacturers, managed care organizations, and pharmacy benefit managers (PBM) serving Medicare Part D program members. PBMs, Medicare Advantage organizations, and Part D sponsors should monitor these changes in the interest of maintaining compliance and providing input on regulatory proposals that may influence their business operations or compensation structures in the future....