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Another Salvo in the War for Control of Contractor "Systems" Approval

Client Alert | 1 min read | 08.20.10

In the "Report on Allegation of Unsatisfactory Conditions Regarding Actions by the Defense Contract Management Agency, Earned Value Management Center" (July 28, 2010 http://www.dodig.mil/Audit/reports/fy10/apo/D-2010-6-002.pdf), the DoD Inspector General recommended that the Defense Contract Management Agency "prohibit joint surveillance reviews or other joint activities with a contractor" in order to avoid compromising DCMA's "independence" and to take action to increase DCAA "participation" in Earned Value Management Systems audits. While DCMA did not concur in many of the recommendations in the IG report, if the IG recommendations were adopted they would inevitably be applicable to other contractor "systems" issues, make it more difficult for contracting officers to resolve systems issues raised by DCAA, and have a decidedly negative impact on compliance and contract administration activities in the procurement process.

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Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....

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