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Regulatory Reform › Notice and Comment

Faegre Drinker Biddle & Reath LLP

HHS Rescission of the Richardson Waiver and Unintended Legal Consequences for Drug and Device Manufacturers

Faegre Drinker Biddle & Reath LLP on

On March 3, 2025, the U.S. Department of Health and Human Services (HHS) published a policy statement rescinding a decades-old administrative exemption for notice-and-comment rulemaking known as the Richardson Waiver. Written...more

Morgan Lewis

HHS Rescinds Policy Extending Notice and Comment Rulemaking Procedures to Rules for Grants, Public Benefits, and Contracts

Morgan Lewis on

Effective March 3, 2025, the US Department of Health and Human Services (HHS) rescinded its long-standing policy that had waived a statutory exemption under the Administrative Procedure Act (APA) from notice and comment...more

Latham & Watkins LLP

HHS Issues Policy Statement to Expand Use of Rulemaking Without Notice and Comment

Latham & Watkins LLP on

The policy statement aims to bring more rapid action on personnel and management decisions and empowers HHS and each of its offices and subagencies to promulgate or rescind certain rules without a period of notice and comment...more

Venable LLP

California DFPI Seeks Feedback on Expanding Registration and Reporting to New Sectors

Venable LLP on

The California Department of Financial Protection and Innovation (DFPI) is inviting stakeholders to suggest new financial service industries that may need registration and reporting requirements under the California Consumer...more

Foley Hoag LLP - Cannabis and the Law

The DEA’s Rule to Reschedule Cannabis to Schedule III: Process and Timeline

Foley Hoag LLP - Cannabis and the Law on

On April 30, 2024, the Associated Press (AP) reported the Drug Enforcement Administration (DEA) will propose a rule to reschedule cannabis from Schedule I to Schedule III under the Controlled Substances Act (CSA). More...more

Akin Gump Strauss Hauer & Feld LLP

The Export Control Reform Act and Possible New Controls on Emerging and Foundational Technologies

Akin Gump Strauss Hauer & Feld LLP on

• ECRA became law on August 13, 2018. It is the permanent statutory authority for the EAR, which is administered by the U.S. Department of Commerce’s BIS. The new law codifies long-standing BIS policies and does not require...more

Foley Hoag LLP - Environmental Law

Shooting Fish In a Barrel: EPA Loses Another Regulatory Delay Case

Foley Hoag LLP - Environmental Law on

On March 21, 2018, EPA lost yet another regulatory delay case. After the Obama EPA promulgated rules updating requirements concerning certification and use of “restricted use pesticides” in January 2017, the Trump EPA...more

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