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Final Rule on Supply Chain Risk Fails to Provide Additional Guidance, Protection, or Relief from Uncertain Application

Client Alert | 1 min read | 11.02.15

On October 30, DoD published a final rule (a) requiring evaluation of supply chain risk when acquiring information technology that is either a covered National Security System ("NSS"), part of a covered NSS, or in support of a covered NSS; and (b) authorizing DoD to exclude primes or subs from a particular procurement if they fail to mitigate identified supply chain risks adequately. DoD made relatively modest changes to the 2013 interim rule (e.g., removing the flow-down requirement applicable to subs at any tier) but largely rejected industry input (e.g., declining to identify specific standards or controls to mitigate supply chain risk and declining to create a mechanism for challenging exclusion from a particular source selection).


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Client Alert | 2 min read | 03.23.26

ACTS Survey Compliance Deadline Temporarily Extended: What Higher Education Institutions Need to Know

On March 13, a Massachusetts federal district court temporarily blocked the Trump Administration from requiring higher education institutions to respond to the Admissions and Consumer Transparency Supplement (“ACTS”) survey — a new data collection effort mandating that institutions disclose detailed admissions information regarding students’ race and sex to the federal government. In Commonwealth of Massachusetts v. Department of Education, 1:26-cv-11229 (D. Mass.), the court extended the deadline for institutions to respond to the survey from March 18th to March 25th to allow time to consider the case....