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  3. |For Iraq War Items Sole Source Award, COFC Grants Limited Injunctive Relief Despite OCI And CICA Violations

For Iraq War Items Sole Source Award, COFC Grants Limited Injunctive Relief Despite OCI And CICA Violations

Client Alert | 1 min read | 05.21.04

In Filtration Dev. Co. LLC v. U.S. (April 27, 2004), the Court of Federal Claims found (1) that a sole source award for filtration kits (to protect helicopters in Iraq from sand damage) that included a directed subcontract violated organizational conflict of interest (OCI) prohibitions because, even though it had performed no work on that system, the subcontractor held a Systems Engineering and Technical Assistance (SETA) contract for the system, and (2) that the urgent and compelling circumstances justification and approval (J&A) for the sole source action, despite explicitly authorizing procurement of a larger number of kits than already ordered by the prime from the designated subcontractor, was limited by the scope of the current emergency to the smaller order already placed. The court granted injunctive relief, but only to preclude further contracts or orders without a new J&A, and declined to enjoin the government from including the directed subcontractor in future competitions or contracting actions because, inter alia, the OCI could be waived.

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Client Alert | 7 min read | 08.19.26

CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care

On August 13, 2026, the Centers for Medicare and Medicaid Services (CMS) published its final rule banning the use of federal funds — through Medicaid and the Children’s Health Insurance Program (CHIP) — to pay for gender-affirming care for children and youth. The final rule takes effect October 13, 2026 (“Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children”). While CMS finalized several key elements of its late-2025 proposed rule (Client Alert December 24, 2025), the proposed Medicare hospital Condition of Participation rule remains in proposed form....

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