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The Top FCA Developments Of 2018

Client Alert | less than 1 min read | 02.04.19

From the government’s renewed use of its dismissal authority to changes to the policy on corporate cooperation credit, the second year of False Claims Act (FCA) enforcement under the Trump administration was defined by several announcements concerning how the Department of Justice (DOJ) will pursue cases under the FCA. These policy reforms are among the many FCA developments highlighted by C&M attorneys in a "Feature Comment" published in The Government Contractor, which considers key issues such as small business fraud, materiality post-Escobar, trade and domestic preferences, and the Supreme Court’s review of a circuit split concerning the statute of limitations.

Insights

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. ...