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Agency's Stafford Act Interpretation Rejected

Client Alert | less than 1 min read | 11.12.07

In Executive Protective Security Service, Inc. (Oct. 22, 2007, http://www.gao.gov/decisions/bidpro/2999543.pdf), GAO sustained the protest on the basis that FEMA had improperly interpreted the “doing business primarily” eligibility requirement of the Robert T. Stafford Disaster Relief and Emergency Assistance Act. GAO determined that the act’s plain language and legislative history required that a firm must conduct a majority of its business in the designated disaster area to be considered for a Stafford Act award.

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Client Alert | 4 min read | 09.16.26

CMS Offers Guidance as Scrutiny Rises Over ABA Therapy in Medicaid

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021. ...