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Proposed Far Rule Would Require Many Federal Contractors And Subcontractors To Adopt Ethics Program

Client Alert | less than 1 min read | 02.16.07

Proposed changes to the FAR 72 Fed. Reg. 7588 (Feb. 16, 2007) (to be codified at 48 C.F.R. subpart 3.10) would require companies receiving a federal prime contract or subcontract in excess of $5 million to (1) adopt a written code of ethics and business conduct; (2) adopt an employee ethics and compliance training program; (3) adopt an internal control system; and (4) display agency Office of Inspector General hotline posters in common work areas where covered contracts are being performed. Contracts performed outside of the United States, whose performance period is less than 120 days, or that are “commercial item” contracts under FAR Part 12, would be exempt.

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Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....