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 | 6 min read | 03.06.26
Tri-Agencies Release Fourth Mental Health Parity Report to Congress
On March 3, 2026, the Department of Labor (DOL), Department of Health and Human Services (HHS), and Department of the Treasury (TREAS) — collectively, the “Tri-Agencies” — published their fourth annual report to Congress on enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA). The 2025 Report demonstrates a shift in approach by the Tri-Agencies in its tone and content and suggests that federal regulators, and the DOL in particular, are not as active as they previously were in MHPAEA enforcement. However, federal enforcement remains ongoing, and state enforcement of mental health parity laws continues to grow. Plans and issuers must continue to maintain comprehensive compliance processes and documentation for MHPAEA compliance.
Client Alert | 4 min read | 03.05.26
Client Alert | 8 min read | 03.05.26
Client Alert | 4 min read | 03.04.26
Sixth Circuit Finds EFAA Arbitration Bar to Entire Case — Not Just Sexual Harassment Claims
