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The federal government must publish new procedures 90 days after the 2014 Intelligence Authorization Act is signed. These procedures will become effective upon publication.
Intelligence community contractors will be...more
In recognition of the increasing threat that cyber-attacks pose to the state's infrastructure and the considerable costs that government and private sectors are estimated to spend on cyber security (more than $70 billion...more
In the final days of 2013, the White House Office of Management and Budget (OMB) released for publication long-awaited final guidance on administrative requirements, cost principles and audit requirements pertaining to...more
On December 17, 2012, the Ministry of Health (“MOH”) issued the Tentative Guidelines for Centralized Procurement of High Value Medical Consumables (the “Guidelines”) with immediate effect, with an aim to control health care...more
CMS is seeking comments from hospitals, electronic health record (EHR) vendors, and other interested parties regarding whether hospitals could be ready as early as January 1, 2014, to electronically report patient-level...more
Healthcare suppliers and service providers live in a regulated world. They are constantly under audit scrutiny. Sometimes federal agencies (i.e private contractors) conduct the audits; other times state agencies conduct the...more
On January 2, 2013, President Obama signed the 2013 National Defense Authorization Act for 2013 (NDAA) into law. Each year Congress passes the NDAA to authorize funding levels for Department of Defense (DoD) programs and...more
Although the Department of Health and Human Services (HHS) issued the final conflict of interest rule last year, many entities conducting research that is funded under Public Health Service (PHS) grants, cooperative...more
In an opinion that continues a welcome trend in False Claims Act cases, Judge Saylor of the United States District Court for the District of Massachusetts has dismissed a relator’s FCA complaint for failing to plead facts...more
The FY-2012 National Defense Authorization Act reauthorized the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs through 2017. Administered by the U.S. Small Business...more
On October 10, 2012, two pro-life groups petitioned the U.S. Supreme Court to review and reverse the U.S. Court of Appeals for the District of Columbia Circuit Court’s decision allowing the continued federal funding of...more
On October 8, 2012, the House Intelligence Committee issued a damning bi-partisan report on what it perceived to be national security risks posed by two Chinese telecommunications companies: Huawei and ZTE. The committee...more
A recent Order (MO-2786) of a Senior Adjudicator of the Office of the Ontario Information and Privacy Commissioner provides a useful guide for organizations wishing to protect confidential and financial information submitted...more
A new rule proposed for federal government contractors will require that all federal contracts over $100,000 (including contracts for commercial items and those to small businesses) will have to include a clause requiring the...more
Government contractors should take note of a newly proposed FAR rule that requires basic safeguards for government contractor information systems. Under the proposed rule, government contractor information systems that...more
Many of the high-profile False Claims Act (FCA) cases against the health care industry have involved allegations that false claims for payment were submitted for items or services provided to Medicare or Medicaid...more
On May 11, 2012, the Department of Defense (DoD) published an interim final rule expanding its pilot program institutionalizing the sharing of cyber threat information between DoD and its contractors. Comments on the rule are...more
Science Applications International Corp (SAIC) has agreed to pay more than $500 million in fines and penalties to settle federal charges alleging that the outsourcing company overcharged the city of New York for work and...more
Congress currently is considering various cybersecurity bills. While Congress debates cyber legislation, the executive agencies are adopting regulations governing how government contractors handle contract-related information...more
On New Year's Eve, President Obama signed the National Defense Authorization Act for Fiscal Year 2012, which included Section 815 that addressed several revisions to the rights the Government obtains in technical data...more
On December 31, 2011, President Obama signed the National Defense Authorization Act for 2012, which included the SBIR/STTR Reauthorization Act of 2011 (the "Act"). H.R. 1540-526, Division E. Many changes, large and small,...more
On November 7, 2011, the U.S. State Department published a proposed rule amending the International Traffic in Arms Regulations (“ITAR”) by narrowing the categories of aircraft and related equipment controlled on the United...more
In late September, Flowserve Corporation (“Flowserve”) and a number of its subsidiaries agreed to settle alleged export violations with the Department of Commerce, Bureau of Industry of Security (“BIS”) for $2.5 million, and...more
Last week, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) published its work plan for the 2012 fiscal year in which it described its primary objectives for the year. We identify below, by...more
Those familiar with Government contracting know at least a little bit about the elusive and fickle regulatory requirements for Independent Research and Development (“IR&D” or “IRAD”) costs. IR&D is a means by which the U.S....more
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