Bad Alchemy: Turning Estimates Into Fraud
Client Alert | less than 1 min read | 02.08.06
Building on comments at the Nash & Cibinic Roundtable, David Bodenheimer challenges the oxymoronic trend of government agencies and qui tam whistleblowers to assert defective pricing or false claims based upon second-guessing poor estimates. In his article "'False' or 'Inaccurate' Estimates" published in the December 2005 Briefing Paper (http://www.crowell.com/pdf/Expertise/GovtContracts/BriefingPapers_Bodenheimer.pdf), he explains that estimating -- due to its inherently risky and predictive nature -- requires judgmental forecasts long recognized as appropriate by government pricing guidelines and not suitable for defective pricing and fraud suits complaining about bad estimates of future events.
Insights
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
