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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.    

Insights

Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....