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Cardinal Change In MOD Requires Competition

Client Alert | less than 1 min read | 08.23.04

Continuing a recent trend of success by bid protesters in the Court of Federal Claims, in CW Gov't Travel, Inc. v. U.S. (Aug. 3, 2004), the court agreed that a modification to an existing contract of a competitor called for services outside the general scope of the original contract and that the work had to be competed. The protester attained this relief even though the mod had been effected a year previously.

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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....