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Small Biz Get An Extra Two Years for Revenue Lookback

Client Alert | 1 min read | 12.20.18

On December 17, 2018, President Trump signed into law H.R. 6330, Small Business Runway Extension Act of 2018, which amends the Small Business Act to extend the time period over which the size standard is measured for business concerns providing services. Whereas previously the Small Business Act used the annual average receipts over a three-year period to determine size for services contracts, size for services contracts will now be measured by the annual average receipts over a five-year period. The act does not amend any revenue limits or impact size standards for manufacturing contracts which are based on employee count. While the change to the act is effective immediately, the Small Business Administration has yet to implement the corresponding changes to its regulations and we expect them to do so shortly.

Insights

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....