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Bah Humbug: Appropriations Bill Contains Lump of Coal for DoL on "Fair Pay" Funding

Client Alert | less than 1 min read | 12.21.15

The FY 2016 Omnibus Appropriations bill, passed on December 18, 2015, did not appropriate funds to establish an Office of Labor Compliance within DoL to implement the "Fair Pay and Safe Workplaces" Executive Order, as requested by the Obama Administration. By declining to appropriate the requested funds, Congress pumped the brakes on the implementation of the EO, which, as described here, would impose burdensome compliance and reporting obligations on federal contractors and subcontractors.

Insights

Client Alert | 2 min read | 02.03.26

CMS Doubles Down on RADV Audit Changes

On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025....