News & Analysis as of

Audits Public Comment

Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

DirectEmployers Association

OFCCP Has Formally Proposed to Resurrect Monthly CC-257 Employment Utilization Reports for Construction Contractors to Give OFCCP...

Proposed Version of Reinstated Form Would Have Multiple Changes- In a move perhaps akin to a vampire or zombie story, OFCCP is seeking public comments regarding its sudden proposal (not mentioned in its Semi-Annual...more

Proskauer - Health Care Law Brief

NYS DFS Revisits PBM Regulation with Scaled-Back Draft Rules

On February 6, 2024, the New York State Department of Financial Services (“DFS”) released “pre-proposed” consolidated rulemaking related to the business practices of Pharmacy Benefit Managers (“PBMs”) licensed to operate in...more

WilmerHale

California Privacy Protection Agency Emphasizes Enforcement and Expresses Opposition to Federal Privacy Legislation at March...

WilmerHale on

On Friday, March 3, 2023, the California Privacy Protection Agency (CPPA) held a public board meeting. Though the meeting focused primarily on the Agency’s budget and various administrative issues (e.g., subcommittee...more

Proskauer - Law and the Workplace

New Proposed Rules on New York City Law to Regulate Use of Automated Hiring Tools

On Friday, September 23rd, the New York City Department of Consumer and Worker Protection issued a Notice of Public Hearing and Opportunity to Comment on Proposed Rules (“Proposed Rules”) related to Local Law 144 (“the Law”),...more

DirectEmployers Association

OFCCP Week In Review: September 2022

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Cynthia L. Hackerott. In today’s edition,...more

DirectEmployers Association

OFCCP’s Proposed NPRM Walks Backwards Promising Less Transparency in Audits and Unknown, But Different (to come), Evidentiary...

Contractors Will Not Like OFCCP’s Assault on Their Rights or OFCCP Interpretations of Title VII Law Requirements Changing Like the Weather - But This Will Happen as OFCCP Continues Its New March to be a Highly Politicized...more

DirectEmployers Association

OFCCP Week In Review: March 2022 #3

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more

Eversheds Sutherland (US) LLP

Last minute addition to your summer reading list: Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451...

On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more

Proskauer - Government Contractor Compliance...

OFCCP Takes Next Step In Establishing An Annual AAP Certification Program

On September 14, 2020, the Federal Register published an information collection request (“ICR”) by the OFCCP in which the agency discloses that it “seeks authorization for an annual Affirmative Action Program online...more

DirectEmployers Association

OFCCP Week In Review: September 2020 #2

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more

K&L Gates LLP

K&L Gates Triage: Recent Developments Impacting Drug Pricing and the 340B Program: Part 2

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In Part Two of this two-part series on recent developments in pharmacy law and the 340B drug pricing program, Richard Church and Ryan Severson discuss several recent developments related to the 340B drug pricing program,...more

Proskauer - Government Contractor Compliance...

OFCCP Revises Proposed Audit Scheduling Letters

Quick Hit: On June 28, 2019 The Office of Management and Budget (“OMB”) published notice that “OFCCP seeks to revise the letters used to schedule compliance evaluations.” As we previously reported, OFCCP proposed changes to...more

Sullivan & Worcester

SEC Proposes Amendments to Accelerated and Large Accelerated Filer Definitions

Sullivan & Worcester on

The SEC today voted to propose amendments to the definitions of "accelerated filer" and "large accelerated filer," which are used to determine, among other things, the filing deadlines for periodic reports and the requirement...more

Sheppard Mullin Richter & Hampton LLP

CMS Proposes To Force Hospices to Specify Unrelated Treatments

In its FY 2020 proposed hospice update, CMS proposes two changes of significant interest to providers: • Shifting $500 million of reimbursement from routine to enhanced care levels; and • Requiring providers to notify...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Issues Concept Release Seeking Feedback on Business and Financial Disclosure Requirements"

On April 13, 2016, the U.S. Securities and Exchange Commission (SEC) issued a concept release seeking feedback on ways to modernize the business and financial disclosure requirements of Regulation S-K. The 341-page release...more

McDermott Will & Emery

A Very Scary Time of the Year: MTC Joint Audit Selection

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With both Halloween and the Multistate Tax Commission (MTC) Income Tax Audit selection nearing, taxpayers should prepare themselves for the possibility of being spooked in the near future. On Thursday, October 30, from 2-4...more

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