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The FAR Regulators Enter the Cyber Fray

Client Alert | 1 min read | 08.28.12

On the heels of the latest demise of cyber legislation, the FAR Council has proposed new cybersecurity regulations for safeguarding government information ("other than public information") residing on or transiting through contractors' systems. While lacking some of the detail (such as certain NIST standards) contained in a predecessor proposal by DOD, the proposed FAR rule establishes broad requirements for basic cybersecurity safeguards for "all Federal contractors and appropriate subcontractors," including mandates for  (1) "the best level of security and privacy available, given facilities, conditions, and environment"; (2) "at least one physical and one electronic barrier" for such information; (3) "sanitization" prior to disposal of information and electronic media; and (4) "intrusion protection," such as "updated malware protection services."

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....