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National Archives Issues Non-FAR-Based Guidance for Controlled Unclassified Information

Client Alert | 1 min read | 02.13.18

The Information Security Oversight Office (ISOO) within the National Archives and Records Administration (NARA) has issued guidance relevant to contractors and other non-executive branch entities concerning controlled unclassified information (CUI). Specifically, the ISOO issued CUI Notice 2018-01 regarding information sharing agreements with non-executive branch entities that are not governed by the forthcoming CUI Federal Acquisition Regulation (FAR) Clause, including certain contracts, grants, licenses, and memoranda of understanding. Importantly, the ISOO guidance provides both mandatory and recommended language for inclusion in future information sharing agreements to help ensure the appropriate handling and safeguarding of CUI. While we continue to await a proposed FAR Clause regarding CUI, contractors should benefit from the additional clarity that this ISOO guidance brings in standardizing CUI provisions for non-FAR based agreements.

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Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....