News & Analysis as of

Interim Guidance

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

Bricker Graydon LLP on

Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

Jones Day

PTAB Issues Updated Fintiv Guidance

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After rescinding the June 2022 guidance regarding Fintiv, the PTAB issued updates to how they will consider discretionary denial issues under Section 314(a) on Monday.  ...more

Goodwin

Issue 45: PTAB Trial Tracker

Goodwin on

In Pfizer Inc., v. Sanofi Pasteur Inc., SK Chems Co. Ltd., v. Vidal, 2019-1871 (March 5, 2024), the Federal Circuit affirmed the Board’s conclusions that claims 1–45 of U.S. Patent No. 9,492,559 were unpatentable due to...more

Fenwick & West LLP

Understanding the Latest on Director Review in AIA Proceedings

Fenwick & West LLP on

The NPRM proposals align with interim guidance on requesting director review for key AIA trial decisions. Following the Arthrex v. Smith & Nephew ruling, director review by the USPTO Director remains crucial for addressing...more

ArentFox Schiff

EPA Updates Interim Guidance on Destruction and Disposal of PFAS Wastes

ArentFox Schiff on

On April 8, the US Environmental Protection Agency (EPA) issued interim guidance for public comment regarding the destruction and disposal of per- and polyfluoroalkyl substances (PFAS). Below, we discuss the guidance and...more

Quarles & Brady LLP

FDA Releases Draft Interim Guidance on Bulk Drug Substances in Compounding Under Sections 503A and 503B of FDCA

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The Food and Drug Administration (“FDA”) has released draft interim guidance documents that impact the use of bulk drug substances in compounding under Sections 503A and 503B of the Federal Food, Drug, and Cosmetic Act...more

Holland & Knight LLP

Federal Judge Cites Ambiguous Coding Guidance, Vacates Doctor's Healthcare Fraud Conviction

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A federal judge recently exposed weaknesses in the U.S. Department of Justice's (DOJ) criminal healthcare fraud enforcement efforts by vacating a jury's conviction of a prominent Maryland doctor. On Aug. 4, 2023, a federal...more

Stinson LLP

IRS Issues Interim Guidance on Specified Research or Experimental Expenditures

Stinson LLP on

The Internal Revenue Service (IRS) recently announced in Notice 2023-63 (notice) that proposed regulations regarding specified research or experimental (SRE) expenditures would be forthcoming. Until then, taxpayers may rely...more

Smart & Biggar

PMPRB adopts Amended Interim Guidance pending release of new guidelines

Smart & Biggar on

As previously reported, the Patented Medicine Prices Review Board (PMPRB) proposed amendments in June 2023 to its Interim Guidance (“Amended Interim Guidance”) for reviewing the prices of patented medicines pending the...more

Bass, Berry & Sims PLC

UPDATE: Next Step in SBA’s Implementation of Ultima Ruling to 8(a) Program

Bass, Berry & Sims PLC on

The July 19 Ultima ruling threw the 8(a) program into tumult after the U.S. District Court for the Eastern District of Tennessee found the program’s rebuttable presumption mechanism, used to find social disadvantage, in...more

Eversheds Sutherland (US) LLP

An olive branch or shot across the bow? IRS issues Notice 2023-63 providing welcome substantive Section 174 guidance

The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more

Pillsbury Winthrop Shaw Pittman LLP

The SBA Makes Significant Changes to 8(a) Program

The changes come in response to a court injunction declaring rebuttable presumption for social disadvantage unconstitutional. All pending SBA 8(a) program applications are currently suspended due to an injunction issued by...more

Bass, Berry & Sims PLC

SBA Issues Interim Guidance on 8(a) Program Following Ultima Ruling

Bass, Berry & Sims PLC on

On July 19, the U.S. District Court for the Eastern District of Tennessee ruled in favor of Ultima Services Corporation, prompting the pause of new 8(a) applications and necessitating a reorganization of the program’s...more

Holland & Knight LLP

SBA Releases Interim Guidance on 8(a) Program in Light of Ultima Decision

Holland & Knight LLP on

As announced by U.S. Small Business Administration (SBA) Associate General Counsel for Procurement Law John Klein in an Aug. 17, 2023, webinar, SBA has issued a press release and interim guidance regarding its implementation...more

Pillsbury Winthrop Shaw Pittman LLP

China Finalizes Its First Administrative Measures Governing Generative AI

The interim administrative measures, which are the first comprehensive AI regulations in the People’s Republic of China (PRC or China), apply only to using generative AI technology to provide services to the public within the...more

BCLP

NOW is the Time to Review and Correct Retirement Plan Compliance: IRS Notice 2023-43

BCLP on

There has never been a better time for plan sponsors to prioritize reviewing and self-correcting eligible plan failures. SECURE 2.0, attached to the 2022 year-end Consolidated Appropriations Act, expands retirement savings...more

Society of Corporate Compliance and Ethics...

The NCAA's new charging standard for NIL violations

The National Collegiate Athletics Association (NCAA) released its interim policy regarding name, image, and likeness (NIL) for NCAA student-athletes in July 2021. Since then, the NCAA has released several clarifying guidance...more

King & Spalding

EUROPE – New Interim Guidance on Parallel EMA-HTA Body Scientific Advice

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On July 3, 2023, the European Medicines Agency (“EMA”) and the European Commission published a Guidance on Parallel EMA/HTA body Scientific Advice for the Interim Period (“Guideline”). The Guideline organizes parallel...more

Eversheds Sutherland (US) LLP

IRS issues transitional guidance regarding reporting and paying the stock buyback tax

On June 29, 2023, the Internal Revenue Service (IRS) issued Announcement 2023-18 (the Announcement), which provides transitional guidance with respect to the stock repurchase excise tax under section 4501 (the Buyback Tax)....more

Williams Mullen

PFAS and Your Wastewater Discharge Permit: What to Know and How PFAS Affects Permit Requirements

Williams Mullen on

Beginning with the PFAS Action Plan of 2019, it became clear to industry observers and environmental professionals that EPA intends to regulate PFAS compounds in industrial wastewater permits. The Action Plan identified an...more

Faegre Drinker Biddle & Reath LLP

IRS Issues Interim Guidance on SECURE 2.0 Self-Correction Expansion

The IRS recently issued Notice 2023-43 (Notice) to provide interim guidance on Section 305 of SECURE 2.0 Act of 2022 (SECURE 2.0), which significantly expanded self-correction under the Employee Plans Compliance Resolution...more

Smart & Biggar

PMPRB releases proposed amendment to Interim Guidance for comment

Smart & Biggar on

On June 20, 2023, the Patented Medicine Prices Review Board (PMPRB) released a proposal to amend the Interim Guidance, which sets out the approach for reviewing the prices of patented medicines under the July 1, 2022...more

Snell & Wilmer

Colorado River Update:  Reclamation Issues FR Notice for Post-2026 Operational Guidelines and Strategies

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The U.S. Bureau of Reclamation has initiated the Environmental Impact Statement (“EIS”) process for post-2026 operational guidelines and strategies of Lake Powell and Lake Mead. This process is in addition to the Draft...more

Proskauer - Employee Benefits & Executive...

Self-Help: The IRS Provides Interim Guidance for Self-Correction under the SECURE Act 2.0

The IRS recently issued Notice 2023-43 providing new interim guidance for self-correction of plan errors. This guidance applies to corrections made prior to the anticipated issuance of revisions to the Employee Plans...more

McDermott Will & Emery

Treasury, IRS Issue Interim Guidance on SECURE 2.0 Act’s Changes to EPCRS

Recently issued Notice 2023-43 provides interim guidance on certain changes to the Employee Plans Compliance Resolution System (EPCRS) made by the SECURE 2.0 Act of 2022. In particular, the notice addresses how plan sponsors...more

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