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Pre-Award Key Personnel Departure Creates Catch-22 – Do I Tell or Not?

Client Alert | less than 1 min read | 12.24.15

In Pioneering Evolution, LLC (Dec. 8, 2015), GAO agreed with the Navy's rejection of an offer as technically unacceptable for failure to satisfy a material solicitation requirement when the protester had notified the Navy after submission of final proposal revisions (FPRs) but before award that one of its proposed key personnel had accepted another position and was no longer available to perform. GAO asserted that the protestor was required to notify the Navy but that it had no right to substitute a qualified replacement, confirming that offerors are at risk if they inform an agency of key personnel departures post-FPR.

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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....