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Congress poised to invalidate agency guidance document in unprecedented use of the Congressional Review Act – could it provide a roadmap for relief for the health industry?


If the Government Accountability Office (GAO) determines that a guidance document is a "rule" within the meaning of the Congressional Review Act (CRA), it is the date of GAO's determination — not the date of original issuance — that starts the clock for Congress to invoke the process of rescission under the CRA.

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