Final Rule Requires Technical Interchange for IR&D Cost Allowability
Client Alert | 1 min read | 11.14.16
On November 4, 2016, DoD issued a final rule requiring contractors performing IR&D projects initiated in FY2017 or later to engage in a technical interchange with DoD, and report the occurrence of this interchange, before the costs for such projects may be deemed allowable (a topic previously discussed here). Although the rule is stated to be intended to promote DoD awareness of IR&D projects and provide feedback to contractors, it is likely to impose an administrative burden on contractors and DoD alike and could have a chilling effect on IR&D investment, particularly because it is silent regarding the allowability of IR&D costs if DoD fails to engage.
Contacts
Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
