The State of the Union, Suspension and Debarment Edition
Client Alert | less than 1 min read | 06.22.16
On June 15, 2016, the Interagency Suspension and Debarment Committee transmitted its annual report to Congress concerning the status of the federal suspension and debarment system, known as the “873 Report” after section 873 of Public Law 110-417, which requires the annual reporting. The 873 report evidences a slight decline in suspensions, proposed debarments, and debarments from FY 2014 to FY 2015, and an overall increase in the use of “alternatives to exclusion” such as administrative agreements (up 25 percent), and show cause letters (up 30 percent).
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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.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
