June 8 FAC Confirms FAR Changes
Client Alert | 1 min read | 06.09.05
FAC 2005-04, published on June 8, 2005 (70 Fed. Reg. 33654-33677), either adopts interim rules previously promulgated or makes relatively minor changes to existing rules concerning allowability of deferred compensation and post-retirement benefit costs, SDB and HUBZone evaluation preferences, Davis-Bacon Act application, telecommuting by federal contractors, incentives for performance-based contracting for services, and use of labor standards on construction contracts. The principal substantive changes in the FAC are the elimination of the commercial pricing exemption for noncommercial modifications to commercial items exceeding the greater of $500,000 or 5 percent of the total contract price (applicable only to contracts with DoD, NASA, or the Coast Guard) and complex changes to the rules concerning recognition of gains and losses and allowable rental costs in connection with sales and leaseback transactions that should be considered in planning such transactions.
Insights
Client Alert | 5 min read | 04.13.26
EU Pharma Package: Global (Orphan) Marketing Authorization Compromise Proposal
In our fifth alert in this EU Pharma Package Series, we provided an analysis of the background and ongoing legal debates regarding the concept of the global marketing authorization (GMA). We discussed in particular the missed opportunities in the Pharma Package to further codify and clarify the GMA, in view of its central role in determining the regulatory data protection (RDP) rights of a medicinal product.
Client Alert | 4 min read | 04.13.26
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Client Alert | 2 min read | 04.10.26
