News & Analysis as of

Interim Final Rules (IFR) New Guidance

WilmerHale

US Export Controls on “AI Diffusion” Officially Paused, but New Guidance Elevates Risk for AI-Related Exports

WilmerHale on

On May 13, 2025, the Department of Commerce formally signaled its intention to rescind the Biden Administration’s Framework for Artificial Intelligence Diffusion (AI Diffusion Rule) two days before the January 2025 Interim...more

Bowditch & Dewey

Corporate Transparency Act – Yes, it’s Back, but no Fines or Penalties for Now

Bowditch & Dewey on

On February 27, 2025, in a move to comply with the Treasury’s commitment to reducing regulatory burdens on businesses, FinCEN announced that it will not impose fines or penalties or take other enforcement actions against any...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - August 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Foley Hoag LLP

OFAC Issues Guidance Concerning Statute of Limitations Extension

Foley Hoag LLP on

On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50 (the “Act”). By doing so, the statute of limitations (“SoL”) for violations, both criminal and civil, of IEEPA...more

Fenwick & West LLP

OFAC Publishes Guidance on 10-Year Sanctions Violations Statute of Limitations

Fenwick & West LLP on

On July 22, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued guidance addressing the April 2024 extension of the statute of limitations for sanctions violations from five years to 10...more

Davis Wright Tremaine LLP

OFAC Provides Guidance on Extended Statute of Limitations

As we previously reported, effective April 24, 2024, the statute of limitations for most civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) or the Trading with the Enemy Act (TWEA) has...more

King & Spalding

Agencies Issue Informal No Surprises Act IDR Guidance on Batching and Air Ambulance Disputes

King & Spalding on

On November 28, 2023, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) issued two sets of FAQs on aspects of the No Surprises Act (NSA) Independent Dispute Resolution Process (IDR...more

McDermott Will & Emery

CMS Downshifts on Expectations for Covered Healthcare Provider Staff COVID-19 Vaccination

McDermott Will & Emery on

CMS released guidance for surveyors that provides leeway in surveying for compliance with the November 2021 interim final rule with comment that imposed a vaccination mandate for most staff at certain covered provider types....more

Williams Mullen

New Lifetime Income Illustrations Required This Year

Williams Mullen on

The Setting Every Community Up for Retirement Act (the “SECURE Act”), passed at the end of 2019, adds a participant disclosure requirement that addresses a long-held concern of lawmakers that many participants are not...more

Benesch

Updated Deadlines and Interpretive Guidance from CMS for Compliance with COVID-19 Vaccination Standards

Benesch on

Updated January 21, 2022 - In response to the U.S. Supreme Court’s decision on January 13, 2022, upholding the Health Care Staff Vaccination Standards for certain Medicare- and Medicaid- certified providers and suppliers...more

Epstein Becker & Green

Podcast: No Surprises Act: New Rules and Guidance for Stakeholders (Part 1) - Diagnosing Health Care

Epstein Becker & Green on

The No Surprises Act (NSA) will go into effect on January 1, 2022. Since our last episode on the topic, the federal government has issued additional interim final rules and guidance to implement the NSA, including the second...more

Dorsey & Whitney LLP

CMS’ COVID-19 Vaccine Mandate: What Health Care Providers Need to Know

Dorsey & Whitney LLP on

Last week, the Centers for Medicare and Medicaid Services (CMS) and the Occupational Safety and Health Administration (OSHA) published their much-anticipated rules mandating COVID-19 vaccinations. ...more

Stinson LLP

CMS Issues its COVID-19 Vaccine Rule for Health Care Employers

Stinson LLP on

As directed by President Biden in September, the Centers for Medicare & Medicaid Services (CMS) issued its interim final rule on November 4, 2021 mandating COVID-19 vaccines for a broad group of health care workers....more

Foley & Lardner LLP

Rising Importance of Sub-Regulatory Guidance in False Claims Act Cases

Foley & Lardner LLP on

On July 1, 2021, United States Attorney General Merrick Garland rescinded the Brand Memorandum and the Sessions Memorandum, which directed Department of Justice (DOJ) attorneys to refrain from using agency guidance to bring...more

Fisher Phillips

July 2021: The Top 14 Labor And Employment Law Stories

Fisher Phillips on

It’s hard to keep up with all the recent changes to labor and employment law. While the law always seems to evolve at a rapid pace, there have been an unprecedented number of changes for the past few years—and this past month...more

Faegre Drinker Biddle & Reath LLP

Part One of Surprise Medical Billing Regulatory Guidance Outlines Specific Required Changes to Group Health Plan Payment...

The No Surprises Act (the “NSA”), which was signed into law at the end of 2020 as part of the Consolidated Appropriations Act, is designed to protect consumers from unexpected medical bills. The NSA generally applies to...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Initial No Surprises Act Regulations Provide Some Clarity for Employer Plans

Plan participants can be hit with surprise medical bills when they receive care from out-of-network providers. Sometimes, this happens when participants do not know that the care they are receiving is from an out-of-network...more

Proskauer Rose LLP

PBGC Issues Guidance on New Special Financial Assistance Program for Troubled Multiemployer Pension Plans

Proskauer Rose LLP on

As we previously reported, the American Rescue Plan Act of 2021 (“ARPA”) created a special financial assistance program that is administered by the Pension Benefit Guaranty Corporation (“PBGC”) and intended to extend the...more

Schwabe, Williamson & Wyatt PC

The Lender’s Role in the PPP Loan Review Process - After the Economic Aid Act: An Updated Guide to the PPP Loan Forgiveness Review...

Lenders play a large role in the Paycheck Protection Program (“PPP”) loan forgiveness review and appeals process. The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “Economic Aid Act” or “PPP2...more

Schwabe, Williamson & Wyatt PC

Initial Takeaways and Agency Guidance for the Latest PPP Updates - After the Economic Aid Act: An Updated Guide to the PPP Loan...

On January 19, 2021, the Small Business Administration (the “SBA”) in consultation with the Department of Treasury (“Treasury”) posted new forgiveness application forms and the Interim Final Rule on Loan Forgiveness...more

Schwabe, Williamson & Wyatt PC

Economic Aid Act: 10 Things to Know about Second Draw PPP Loans - Update

Late on January 6, 2021, the Small Business Administration (the “SBA”) and the Department of Treasury released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Second Draw Loans”...more

White and Williams LLP

PPP 2.0: Welcome, But Still Too Complicated?

White and Williams LLP on

While the arrival of vaccines for the coronavirus have us seeing the proverbial light at the end of the COVID-19 tunnel, many small businesses, particularly in industries such as travel, hospitality and specialty retail,...more

Downs Rachlin Martin PLLC

New SBA Guidance on the PPP Changes and Second Draw PPP Loans

On December 27, 2020, a new COVID-19 relief bill, the Consolidated Appropriations Act, 2021, passed into law. A portion of that bill, the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “Economic...more

Snell & Wilmer

SBA Issues Interim Final Rules for PPP “Second Draw” Loans and Existing PPP Loans

Snell & Wilmer on

On January 6, the Small Business Administration (SBA) issued its Interim Final Rule (IFR) for the original Paycheck Protection Program (PPP-1) to reflect changes to the program included in the recent Economic Aid to Hard-Hit...more

Schwabe, Williamson & Wyatt PC

A Guide to the SBA PPP Loan Forgiveness Review Process - Update #3

Borrowers applying for loan forgiveness under the Small Business Administration’s (“SBA”) Paycheck Protection Program (“PPP”) should familiarize themselves with the SBA guidance regarding the loan forgiveness review process....more

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