For Whom Does the Appeal Clock Toll? Vitiation vs. Finality
Client Alert | 1 min read | 01.12.16
In Guardian Angels Med. Serv. Dogs Inc. v. U.S. (Jan. 8, 2016), the Federal Circuit held that a CO's request to evaluate additional information after a default termination "vitiated the finality" of the termination and reset the 12-month appeal clock, even though the CO neither received new information nor spent any time reconsidering her decision. Reversing the CFC's dismissal of the appeal as time-barred, the court held that, when a CO "evince[s] a clear willingness to consider additional evidence," the appeal period begins anew, rather than merely being suspended, and explained that "whether the contracting officer 'spends time' considering the request is not the proper standard."
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Client Alert | 4 min read | 10.21.25
Pivot Point for 340B: HRSA Rebate Model Pilot Program Approaches Launch
The deadline for Department of Health and Human Services (“HHS”) to notify approved manufacturers of acceptance into the 340B Rebate Model Pilot Program has passed, and stakeholders across the healthcare industry should start planning for compliance and operational changes. The Model Pilot Program may also face legal challenges that could delay or disrupt implementation.
Client Alert | 5 min read | 10.20.25
What’s new for Belgian Construction Contracts under the New Book 7 of the Civil Code
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