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Sequestration Found Valid Basis for Canceling Solicitation

Client Alert | less than 1 min read | 09.23.13

In Vinculum Solutions, Inc. (Aug. 5, 2013), GAO, relying on the "broad discretion" afforded to agencies to define their needs and manage their procurements, concluded that the IRS's need to reduce costs due to the ongoing budget sequestration was a valid basis for canceling a solicitation. This appears to be the first decision in which GAO has considered the impacts of sequestration on the procurement process, and it may green-light similar actions in the months ahead for agencies coping with the ongoing sequester and the uncertainties of the FY14 appropriations process.


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Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....