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Tough (Tax) Break: Federal Tax Delinquency and Felony Convictions Could Bar Corporations from Awards

Client Alert | 1 min read | 10.05.16

The FAR Council published a final rule on September 30 that, effective immediately, adopts an interim rule that requires any corporation responding to a federal solicitation to represent whether it has (1) any unpaid federal tax liability that has been assessed and is not being appealed or paid in a timely manner or (2) a felony conviction under any federal law within the preceding 24 months. As further explained here, any affirmative disclosure would create an automatic bar against contract award, unless the agency’s suspension and debarment official has considered the matter and determined that further action is not necessary to protect the government’s interests.

Insights

Client Alert | 4 min read | 08.29.25

Gender-Affirming Care Targeted for Potential False Claims Act Enforcement

On August 19, 2025, the Office of Personnel Management (OPM) informed insurers participating in the Federal Employees Health Benefits or Postal Service Health Benefits programs that gender-affirming care would no longer be covered for federal workers starting in 2026. This coverage decision is the Trump Administration’s latest action stemming from Executive Order 14187 which aims to prevent certain treatments, such as gender-affirming hormone therapy, surgeries, and puberty blockers for those under the age of 19. As previously discussed, the Administration has also signaled its intent to use various law enforcement tools against gender-affirming care, including  Section 5 of the Federal Trade Commission Act to police false or unsupported claims by medical professionals about gender-affirming treatments....