Awarded a Prior DoD FAR Part 12 Contract? You May Now Have a CID for the Previously Acquired Products/Services!
Client Alert | 1 min read | 05.02.22
On April 28, 2022, the DoD issued a final rule that, effective immediately, requires the government to treat a contract previously awarded using FAR part 12 procedures as a prior commercial item determination (“CID”) for the acquired product or service, unless the head of contracting activity determines that the prior use of FAR part 12 procedures was improper or is no longer appropriate. The final rule implements section 848 of the NDAA for 2018, and applies to DoD contracts regardless of dollar value. Note, however, that prior FAR Part 12 purchases made pursuant to 41 U.S.C. 1903 (for supplies or services to be used to facilitate defense against or recovery from cyber, nuclear, biological, chemical, or radiological attack) or 10 U.S.C. 2380a (for supplies or services from nontraditional defense contractors) may not serve as a prior commercial item determination unless the products or services purchased in that prior acquisition otherwise received a CID.
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Client Alert | 3 min read | 05.23.25
Executive Order Seeks Most-Favored-Nation Drug Pricing and HHS Announces Price Targets
On May 12, 2025, President Trump issued an Executive Order titled "Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients," which aims to reduce the costs of prescription drugs and biologics for American consumers and other payers. This Order revives a plan from President Trump’s first term and follows his April Executive Order, “Lowering Drug Prices by Once Again Putting Americans First,” which also sought to reduce drug prices. With drug prices in the United States nearly three times higher than many other countries, this second Order asks drug manufacturers to adopt Most-Favored-Nation (MFN) pricing for drugs sold in the United States or face potential regulation. MFN pricing would tether drug prices offered in the United States to the lower-cost prices offered in other comparably developed nations, such as Canada, Germany, or the United Kingdom.
Client Alert | 4 min read | 05.22.25
Opportunities for Procurement on the Horizon as UK Concludes Free Trade Agreement With India
Client Alert | 2 min read | 05.22.25
What Trump’s Nominee for IRS Commissioner Could Mean for Employee Retention Tax Credit Enforcement
Client Alert | 3 min read | 05.20.25
