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Significant Revisions to Non-U.S. Content Disclosure and Financing Policies Proposed

Client Alert | less than 1 min read | 10.07.15

The Defense Security Cooperation Agency has informally circulated draft revisions to the August 2009 Guidelines for Foreign Military Financing of Direct Commercial Contracts, which would elaborate on, and in a number of instances significantly change, its policies with respect to the disclosure and financing of U.S., non-U.S., and now "host country" content. Please contact us if you would like to obtain a copy of the draft and/or participate in commenting on the proposal by the due date of November 16, 2015.


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Client Alert | 8 min read | 04.17.26

CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors

On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements....