FEMA to Release New Emergency Management Priorities and Allocation System to Govern FEMA DPA Title I Activities
Client Alert | 1 min read | 05.12.20
On May 13, 2020, the Federal Emergency Management Agency (FEMA) will publish an interim final rule establishing the Emergency Management Priorities and Allocation System (EMPAS) pursuant to Title I of the Defense Production Act (DPA). As drafted, EMPAS will apply beyond the current COVID-19 context and will become part of the Federal Priority and Allocations System (which includes, for example, the Defense Priorities and Allocation System (DPAS) and the Health Resources Priority and Allocations System (HRPAS)). Although largely similar to the DPAS and HRPAS, EMPAS also provides express authorization to issue rated orders to facilitate sales of health and medical resources to third parties while simultaneously rejecting any government financial liability for such orders (44 C.F.R. § 333.12(c) and 333.19). EMPAS is effective immediately upon publication, and comments on the interim final rule will be accepted through June 12, 2020.
Contacts
Insights
Client Alert | 7 min read | 11.05.26
2026 State Attorney General Elections: What Businesses Should Expect
As of November 4, 2026, the state attorney general elections point to increased enforcement in 2027, particularly in consumer protection, antitrust, AI, health care, and data centers.[1] Businesses should prepare for more investigations under existing laws and proposals for new legislation or rules. Campaign commitments indicate priorities, but their timing and implementation remain uncertain.[2]
Client Alert | 3 min read | 11.05.26
Federal, State, and Local Regulators Sue Toast Over B2B Advertising and Subscriptions
Client Alert | 3 min read | 11.04.26
CMS Proposal Would Overhaul Eligibility Rules for ACA Exchanges
Client Alert | 7 min read | 11.04.26
FDA Issues Guidance on Prescription Drug Use-Related Software



