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CAS Offsets Permitted Among Different Contract Types

Client Alert | less than 1 min read | 04.14.06

In an important case of first impression, the Court of Federal Claims in Lockheed Martin Corp. v. United States (Mar. 29, 2006) has held that the cost impact of a Cost Accounting Standard (CAS) noncompliance is the net of all increased costs and all decreased costs that result from the noncompliance on all CAS-covered contracts. The Court rejected the government's argument that decreased costs paid on fixed-price contracts could not be offset against increased costs paid on cost-reimbursement contracts, finding that it "is -- in a word -- wrong."

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Client Alert | 4 min read | 11.09.26

CMS Finalizes Its 2026 Organ Procurement Organization Rule

On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions: ...