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 | 5 min read | 10.22.26
CMS Proposes Major Changes to MA, Part D, and PBM Requirements
On October 16, 2026, the U.S. Centers for Medicare and Medicaid Services (CMS) issued a proposed rule implementing key sections of the Consolidated Appropriations Act (CAA) of 2026, Section 6224 (“Modernizing and Ensuring Pharmacy Benefit Manager Accountability”). The agency also proposes a conforming change mandated by section 6219 of the CAA (“Adjustments to Medicare Part D Cost-Sharing Reductions for Low-Income Individuals”) that would reduce the generic-drug copayment from $1 to $0 for full-benefit dual eligible individuals. Comments to the proposed rule are due December 15, 2026.
Client Alert | 4 min read | 10.22.26
When the Clock Strikes Twice: Crocs Takes Piecemeal ITC Appeals to the Supreme Court
Client Alert | 9 min read | 10.21.26
Client Alert | 2 min read | 10.21.26
