
Publication
Competition Act: Expanded private enforcement rights now in force
On Friday, June 20, 2025, Competition Act amendments came into force that significantly expand private parties’ ability to bring cases to the Competition Tribunal.
United States | Publication | December 2024
In late November 2024, the Centers for Medicare and Medicaid Services (CMS) issued a memorandum to State Survey Agency Directors on revisions to the State Operations Manual, Appendix Q, which provides guidance for surveyors on identifying whether any certified Medicare/Medicaid provider, supplier or laboratory should be cited for immediate jeopardy.
Immediate jeopardy is the most serious deficiency that can be imposed upon a Medicare/Medicaid certified entity and carries with it the strictest sanctions and fines. The memorandum acknowledges that the version of Appendix Q that is being replaced was drafted in 2004, updated in 2019 and is being updated again “to clarify and increase consistency in identifying immediate jeopardy.”
The following are the key updates, among others, that CMS identifies in the memorandum:
While CMS notes in this guidance that the changes are effective “immediately,” there is still a watercolor in the revised State Operations Manual, Appendix Q affixed to the guidance, providing that it is an “Advance Copy.” Our team of experienced lawyers and professionals at Norton Rose Fulbright will continue to closely monitor new guidance from CMS related to immediate jeopardy and are available to answer questions and assist Medicare/Medicaid certified entities in preparation for their next survey.
Publication
On Friday, June 20, 2025, Competition Act amendments came into force that significantly expand private parties’ ability to bring cases to the Competition Tribunal.
Publication
On June 12, the Canadian Securities Administrators published a proposed replacement of National Instrument 43-101 Standards of Disclosure for Mineral Projects and its related companion policy and form of technical report.
Publication
Canada’s Competition Bureau recently released the final version of its guideline on “Environmental claims and the Competition Act” that is intended to help businesses ensure their environmental claims comply with the Competition Act’s deceptive marketing provisions that came into force last June.
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