FAR Council Delivers Last-Minute Holiday Gift by Extending the Comment Period on Proposed Rule Imposing Mandatory Climate Disclosures for Federal Contractors
Client Alert | 1 min read | 12.23.22
On December 23, 2022, the Department of Defense (“DoD”), General Services Administration (“GSA”), and National Aeronautics and Space Administration (“NASA”) extended the comment period on the proposed rule, “Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk,” from January 13, 2023 to February 13, 2023. As we summarized previously, the proposed rule would, if finalized, require thousands of federal contractors to inventory and publicly disclose their Scope 1 and Scope 2 greenhouse gas (“GHG”) emissions, while further requiring “major” contractors to also establish and validate GHG emission-reduction targets tailored to the goals of the Paris Agreement.
The 30-day extension should be a welcome surprise to a wide range of contractors still attempting to unwrap the impact of this largely unprecedented proposal. Crowell’s team stands ready to assist in evaluating the implications and identifying issues worthy of comment.
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Client Alert | 7 min read | 06.26.26
Federal Roundup: Updates for PBMs and Medicare Advantage Organizations
In June 2026, federal regulators and lawmakers continued their efforts to improve drug affordability through targeted reforms. These recent developments will primarily impact pharmaceutical manufacturers, managed care organizations, and pharmacy benefit managers (PBM) serving Medicare Part D program members. PBMs, Medicare Advantage organizations, and Part D sponsors should monitor these changes in the interest of maintaining compliance and providing input on regulatory proposals that may influence their business operations or compensation structures in the future.
Client Alert | 6 min read | 06.26.26
Client Alert | 4 min read | 06.25.26
Twin Executive Orders Seek to Spur Quantum Leap in Technology and Cybersecurity
Client Alert | 7 min read | 06.24.26
