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  3. |Making a List and Checking It Twice: New Rule Requires "Adequacy Checklist" with Forward Pricing Rate Proposals

Making a List and Checking It Twice: New Rule Requires "Adequacy Checklist" with Forward Pricing Rate Proposals

Client Alert | less than 1 min read | 01.09.15

On December 11, 2014, DoD issued a final rule to instruct COs to request that contractors submit a Forward Pricing Rate Proposal "Adequacy Checklist" when submitting their FPRP. Under the rule, both the FPRP and the Adequacy Checklist are due at least 90 days before the proposed effective date of the rates, and DoD cautioned that "the proposed rates are based on forecasts and contractors must provide updates whenever the validity of the agreement may be affected."


Insights

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....