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DOE Solution To Underfunded Pension Plans: Don't Pay For Them

Client Alert | less than 1 min read | 05.03.06

In a "notice" issued April 27, 2006 (http://directives.doe.gov/pdfs/doe/doetext/neword/351/n3511.pdf), DOE announced that "after a date to be negotiated with each Contractor, but no later than March 1, 2007," DOE will try to incorporate provisions in its contracts that would appear to make defined-benefit pensions and retiree medical benefits for new employees unallowable and prohibit reimbursement for plan enhancements unless approved in advance by DOE. It seems unlikely that DOE would have the authority to impose these requirements on existing contracts unilaterally, and some of them, particularly restrictions on the allowability of costs required by collective bargaining agreements, would conflict with existing FAR cost allowability rules.

Insights

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....