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 | 4 min read | 11.09.26
CMS Finalizes Its 2026 Organ Procurement Organization Rule
On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions:
Client Alert | 4 min read | 11.09.26
Pentagon Oversight: Defense Companies Should Prepare for the Next Congress
Client Alert | 7 min read | 11.05.26
2026 State Attorney General Elections: What Businesses Should Expect
Client Alert | 3 min read | 11.05.26
Federal, State, and Local Regulators Sue Toast Over B2B Advertising and Subscriptions
