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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 | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....