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New Reporting Requirements For Grant and Cooperative Agreement Recipients

Client Alert | less than 1 min read | 09.14.10

On September 14, 2010, OMB issued two regulations implementing the Federal Funding Accountability and Transparency Act of 2006 requirements applicable to recipients of federal financial assistance. The first requires (among other things) that, for any new award made after October 1, 2010, applicants and recipients of grants and cooperative agreements must register in the Central Contractor Registration ("CCR"), and the second requires (among other things) that recipients of grants and other forms of federal financial assistance must (subject to a few limitations that generally mirror those in the FAR) provide information about the recipient's executive compensation, first-tier subawards over $25,000, and subrecipients' executive compensation.

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Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....