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DoD Seeks Changes to the Program Fraud Civil Remedies Act

Client Alert | less than 1 min read | 04.26.16

On April 12, 2016, DoD sent its legislative proposal package to Congress and requested (in section 805) changes to the Program Fraud Civil Remedies Act to create, in DoD’s view, a more viable administrative remedy for fraud and false claims totaling less than $500,000. In addition to increasing the ceiling on false claims allegations that can be brought under the PFCRA, DoD seeks to place the decision of whether adequate evidence of liability exists in the hands of suspending and debarring officials, raising for contractors serious concerns, some of which are summarized in the associated blog post.

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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. ...