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White House Delegates Title III DPA Authority to U.S. International Development Finance Corporation

Client Alert | 1 min read | 05.15.20

On May 14, the President issued an Executive Order (EO) delegating funding and loan authority under Title III of the Defense Production Act (DPA) to the U.S. International Development Finance Corporation (DFC) to support domestic production of strategic resources to respond to the COVID-19 outbreak and strengthen domestic supply chains. The DFC’s loan authority under the EO is limited to loans that “create, maintain, protect, expand, or restore domestic industrial base capabilities” supporting “the national response and recovery to the COVID-19 outbreak” or “the resiliency of any relevant domestic supply chains.” Thus, while Congress established the DFC in 2018 to foster America’s investment in overseas development projects, the DFC now is expected to establish a separate investment team to, among other responsibilities, administer loans for this domestic support and to issue new implementing regulations.

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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....