Bundling Rules

News & Analysis as of

Bundled Payments under the Affordable Care Act Continue to Gain Influence

The Center for Medicare and Medicaid Services (CMS) recently announced that it will add roughly 4,100 providers to the 2,400 existing providers testing the possible use of Medicare bundled payment contracts. Providers must...more

FCA Brings Greater Clarity and Rigour to UK’s “Soft Commission” Regime

Changes to the use of dealing commission rules, including a ban on “softing” of corporate access services, reflect the FCA’s continuing objective to ensure that investment managers control the costs that they pass on to their...more

How does French case law deal with bundled software?

Combined offers have always drawn significant attention from French courts. This is all the more the case since combined offers are standard practices when selling computer equipments. Indeed, such equipments are most often...more

Proposed Hospice Rule Focuses on Unbundling of Services

On May 8, CMS released a proposed rule in the Federal Register providing for a payment increase of 1.3 percent for fiscal year (FY) 2015. Among other provisions, CMS’s proposed rule offers hospice providers an update on...more

FCC Rescinds 2010 Cost Allocation Guidance for Bundled Services

Late last Friday, the FCC’s Wireline Competition Bureau released an Order rescinding prior guidance that permitted E-rate applicants to request full funding for certain bundles that included service or equipment components...more

Just in Time for Proxy Season, SEC Provides New Guidance on Shareholder Proposal “Unbundling”

The U.S. Securities and Exchange Commission (SEC) staff recently issued several Compliance and Disclosure Interpretations (C&DIs) providing guidance as to when it is permissible under Rule 14a-4(a)(3) (and its companion rule,...more

SEC Staff Provides Guidance on Unbundling Proxy Proposals to Amend Fund Charters

The staff of the SEC’s Division of Investment Management issued a Guidance Update discussing its position that a single proxy proposal to amend an investment company charter must be “unbundled” to provide a separate vote for...more

SEC Division of Corporation Finance Issues Three C&DIs Relating to “Unbundling Rule”

On January 24, the Securities and Exchange Commission’s Division of Corporation Finance issued three new Compliance and Disclosure Interpretations (C&DIs) with respect to the SEC’s so-called unbundling rule (Rule 14a-4(a)(3)...more

Corporate and Financial Weekly Digest - Volume IX, Issue 5

In this issue: - FTC Announces New Filing Thresholds for Hart-Scott-Rodino Pre-Merger Notifications - SEC Division of Corporation Finance Issues Three C&DIs Relating to “Unbundling Rule” - NFA Members...more

Proxy Statement Unbundling–New Guidance for an Old Rule

With the recent emphasis on proxy statement compensation disclosure, director independence and corporate governance, little attention has been paid to another issue that can delay your proxy statement mailing schedule and...more

SBA Issues Final Rule Implementing The Small Business Jobs Act Of 2010

On October 2, 2013, Small Business Administration (SBA) published a final rule to establish and revise rules and procedures pertaining to small business set-asides, partial set-asides, multiple award contracts (MACs), task...more

Sutherland SALT Shaker: April 2013 Digest

In this issue: - California Court of Appeal: No Man May Profit From His Own Wrongdoing in a Court of Justice - The (True) Object of My Affection: A Nontaxable Stock Screening Service - Alternate Universe...more

Public Company Adviser - April 2013: New Life Breathed into SEC’s Unbundling Rules

The SEC’s “unbundling” requirements have largely been the stuff of SEC lore -- periodically referred to but rarely seen in corporate governance matters. However, thanks to the high profile dispute between David Einhorn’s...more

FCC Seeks Comment on Bundled Components for E-rate

Executive Summary: The Wireline Competition Bureau (“Bureau”) is seeking comment on proposed clarifications to the treatment of ineligible devices when bundled with E-rate eligible components....more

The Ropes Recap: Mergers & Acquisitions Law News

In this issue: *News from the Courts - Refinement re “Don’t Ask, Don’t Waive” Standstill Agreements - Proposed Delaware “Medium-Form Merger” To Create an Alternative to Top-Up Options - Court Rejects...more

Federal Court Halts Apple Shareholder Vote

On February 22, 2013, the U.S. District Court for the Southern District of New York ruled in favor of Greenlight Capital, L.P., et al. ("Greenlight") in the matter of Greenlight Capital, L.P., et al v. Apple, Inc....more

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