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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 | 11.02.26

DOL Finalizes PBM Fee Disclosure Requirements

On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time. ...