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Last Chance to Comment on FASC Rule – More Supply Chain Restrictions Coming

Client Alert | 1 min read | 10.28.20

Companies have less than one week to submit comments regarding a recent interim rule that provides the responsibilities, processes, and procedures for the Federal Acquisition Security Council (FASC), established by the Federal Acquisition Supply Chain Security Act of 2018.  Under the immediately effective interim rule, the FASC is responsible for assessing supply chain risk and making removal and exclusion recommendations to the Secretary of the Department of Homeland Security (DHS), Secretary of the Department of Defense (DoD), and Director of National Intelligence (DNI).  Based on these recommendations, DoD, DHS, and the Office of the DNI (ODNI) then have authority to issue exclusion and removal orders for sources and/or covered articles deemed to pose a supply chain risk from certain procurements.

Click here to read this blog post on Government Contracts Legal Forum.

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Client Alert | 3 min read | 04.25.25

Arkansas Takes Aim at PBM Ownership of Retail Pharmacies

On April 17, 2025, Arkansas recently became the first state to enact broad restrictions on pharmacy benefit managers (“PBMs”) owning retail pharmacies within the state....