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"//signed//" Doesn't Cut It

Client Alert | less than 1 min read | 04.30.08

A claim certification was invalid, and the ASBCA had no jurisdiction to decide the case, when the contractor's president submitted it by email and simply typed "//signed//" above his name. The Board in Teknocraft Inc. (Apr. 3, 2008) acknowledged that both the contractor and the government had used the typed designation "//signed//" in their emails during performance, but held that "//signed//" was not a "discrete, verifiable symbol of an individual" and constituted an "incurable defect" in the certification.

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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. ...