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Follow Up: White House Issues Order under Defense Production Act as Part of COVID Response

Client Alert | 1 min read | 03.23.20

In our March 19 alert, C&M summarized President Trump’s recent executive order invoking the Defense Production Act (DPA). In this follow-up, we provide three separate analyses. First, we provide a discussion of the Defense Production Act, and the implications of the executive order for U.S. businesses and the government in its efforts to reduce the impact of COVID-19. Second, we discuss the current Department of Health and Human Services (HHS) regulations implementing its priorities and allocations authority prior to the executive order. And third, we discuss the manner in which the government most frequently has exercised similar authorities under the DPA pursuant to the Defense Prioritization and Allocation System (DPAS).

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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....

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