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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 | 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. ...