Office of Management and Budget

News & Analysis as of

Alert: New Privacy Training Requirements for Companies with Federal Government Contracts

Effective January 19, 2017, companies awarded federal government contracts will be required to ensure that their employees receive annual privacy training if those employees (1) handle personally identifiable information...more

CFPB issues final rule to adjust civil penalties for inflation

The CFPB has published a final rule to adjust for inflation the civil penalties within its jurisdiction. The adjustments are required by the Federal Civil Penalties Inflation Adjustment Act of 1990 which, pursuant to a 2015...more

USCIS Seeks Public Input on the EB-5 Program

On January 11, 2017, the U.S. Department of Homeland Security’s United States Citizenship and Immigration Services (USCIS) published an Advance Notice of Proposed Rulemaking (ANPRM) to gather information relating to the EB-5...more

May Old Memoranda Be Forgot: White House Issues New Memorandum on Breach Response Plan

The White House Office of Management and Budget (“OMB”) marked the beginning of the 2017 Federal calendar year by issuing a memorandum to all agency and department heads with new guidance on breach preparation and response....more

OMB Reviewing Common Rule Overhaul

On January 4, 2017, the Department of Health and Human Services (HHS) submitted a draft final rule to amend the federal human research regulations to the Office of Management and Budget (OMB). These regulations, often...more

FCC Announces Enhanced Broadband Transparency Disclosures Will Become Effective on January 17, 2017 – Small Provider Exemptions in...

On Thursday, December 16, the FCC announced that the Office of Management and Budget had approved the long-delayed “enhanced” Open Internet transparency requirements, which were originally approved in March 2015. As a result,...more

Trump nominee to head OMB could create roadblock for CFPB regulations

It has been reported that President-elect Donald Trump has nominated South Carolina Republican Congressman Mick Mulvaney to be Director of the Office of Management and Budget (OMB). Mr. Mulvaney has been described as a...more

FCC’s Enhanced Transparency Rule Effective January 17, 2017; Small Provider Exemption Expires

According to a Public Notice the Federal Communications Commission (FCC) released today, on December 15, 2016, the Office of Management and Budget (OMB), has completed its review of the enhanced transparency rule from the...more

OMB Approves Enhanced Transparency Requirements for Open Internet Rules as the Small Provider Exemption Expires; Rules Will Go...

According to a Public Notice the Federal Communications Commission (FCC) released today, on December 15, 2016, the Office of Management and Budget (OMB), has completed its review of the enhanced transparency rule from the...more

Six Ways U.S. Joint Strategic Plan on IP Enforcement Impacts Public Health and Safety

On December 12, 2016, the Office of the U.S. Intellectual Property Enforcement Coordinator (IPEC) in the Executive Office of the President issued a much-awaited interagency plan on intellectual property (IP) enforcement. The...more

California & the Federal Government Expand Laws to Eliminate Wage Disparity

California state legislature amended the Fair Pay Act to prohibit race and ethnicity-based wage differentials and to preclude employers from relying on salary history to justify the wage gaps. In addition, the U.S. Equal...more

The Clock Has Started: What ISPs Need to Do and When to Comply with the FCC’s Broadband Privacy Rules

On December 2, 2016, the Federal Communications Commission (“FCC”) published its Report and Order entitled “Protecting the Privacy of Customers of Broadband and Other Telecommunications Services” (the “Order”) as a final rule...more

Forty-Five Days and Counting for Current HHS Leadership: Implications for Rulemaking

Before we all turn our full attention to the nominations of Representative Tom Price as Secretary of Health and Human Services, and policy consultant Seema Verma to lead CMS, we need to remember that there are still...more

U.S. Government Open Source Software: OMB’s Memorandum on Federal Source Code Policy Exposes IP Ownership Risk

On August 8, 2016, the U.S. Office of Management and Budget (“OMB”) promulgated an Open Source Software (“OSS”) policy via the Memorandum for the Heads of Departments and Agencies, M-16-21 (“Memorandum” or “M-16-21”). The...more

CFPB submits proposal to expand consumer complaint feedback for OMB approval

The CFPB has taken another step towards implementing its proposal to add a survey to its current complaint intake form that a consumer could choose to complete to provide feedback on the company’s response to his or her...more

Uniform Guidance and Procurement Nearly Two Years after 2 C.F.R. Part 200

Since the joint interim final rule, 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), became effective on December 26, 2014: - the U.S....more

Weekly Update Newsletter - November 2016 #3

DEPARTMENT OF DEFENSE, GENERAL SERVICES ADMINISTRATION, AND NATIONAL AERONAUTICS AND SPACE ADMINISTRATION - Clarification of Requirement for Justifications for 8(a) Sole Source Contracts - The Department of Defense...more

Weekly Update Newsletter - November 2016 #2

DEPARTMENT OF DEFENSE - Revised Interim Implementation of Government-wide Guidance for Grants and Cooperative Agreements - The DOD has issued a notice of proposed rulemaking (“NPRM”), the first in a sequence of six...more

The New I-9 is coming

The Office of Management and Budget (“OMB”) has approved the latest revisions to the current Form I-9, which expired on March 31, 2016 but remains valid until the new edition is released.  The new form will replace the 2013...more

EPA Sends RMP Chemical Plant Safety Rule to OMB for Review

EPA has sent its Risk Management Plan revision to the White House Office of Management and Budget for review, calling for a security increase at high-risk chemical facilities. Among other things, this proposal would require...more

Department of Defense Proposes New Uniform Grant and Cooperative Agreement Regulations

On November 7, 2016, the Department of Defense (DoD) published six Notices of Proposed Rulemakings that collectively update the agency's existing interim regulations governing awards of grants and cooperative agreements. 81...more

Major Security Breach Reported to Congress By Federal Bank Regulator

Recently, the Office of the Comptroller of the Currency (OCC) informed Congress that it had suffered a major information security incident. The agency reported that, in November 2015, a former employee downloaded over...more

Office of Management and Budget ( OMB ) Circular A-xxx

Re: Proposed New OMB Circular A-xxx - Dear Ms. Dillon: We are writing to submit comments on the above-referenced proposed Office of Management and Budget (“OMB”) Circular, issued on October 7, 2016, 81 Fed. Reg....more

PilieroMazza Submits Comments on the OMB Circular A-xxx

Yesterday, PilieroMazza filed comments with the Office of Federal Procurement Policy on the proposed new Office of Management and Budget Circular issued on October 7, 2016, 81 Fed. Reg. Included in our comments are:...more

Proposed Circular Could Change the Way the Government Procures Common Goods and Services

On October 7, 2016, the Office of Management and Budget (“OMB”) issued Proposed OMB Circular No. A-XXX, Implementing Category Management for Common Goods and Services. If implemented, the proposed Circular could dramatically...more

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