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CMS Releases Proposed 2014 Star Ratings Methodology

Client Alert | less than 1 min read | 12.12.12

November 30, CMS released its proposed methodology for 2014 Star Ratings for Medicare Advantage and Prescription Drug Plans, also referred to as Plan Ratings. It also includes some potential changes for the 2015 Star Ratings and beyond to give plans advance notice. Comments are due January 3, 2014.


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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...