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With More to Come, DoD Expands Reach of Detection and Avoidance of Counterfeit Parts Requirements

Client Alert | 1 min read | 08.02.16

Today, DoD published a final rule further – but still only partially – implementing the FY12 DoD Authorization Act requirement (since amended) for detection and avoidance of counterfeit electronic parts by imposing on all contractors and subcontractors, including small businesses and suppliers of COTS products and commercial items, traceability obligations and procedures for identifying “contractor approved sources” when electronic parts are unavailable from the original manufacturer or other source identified in the new clause (DFARS 252.246-7008). The new clause also provides for specific procedures to be followed, including notifying DoD and performing authentication, inspection, and testing to industry standards when electrical parts are obtained from subcontractors that refuse flowdown of the clause or from sources other than those expressly authorized under the clause.

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Client Alert | 4 min read | 04.23.26

Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule

In mid-April, a bipartisan coalition of 45 State Attorneys General (AG) submitted a formal letter to the U.S. Department of Labor (DOL) expressing their collective support for a proposed rule (Improving Transparency into Pharmacy Benefit Manager Fee Disclosure, or RIN 1210-AB37), which would — if enacted — impose new disclosure obligations on pharmacy benefit managers (PBM) regulated under the Employee Retirement Income Security Act of 1974 (ERISA)....