CO Must Identify Extension for Final Decision with Precision
Client Alert | less than 1 min read | 05.27.14
In Suh'dutsing Techs., LLC, the ASBCA held that the contractor could appeal a "deemed denial" of its certified claim 60 days after submission of the claim, notwithstanding the contracting officer's statement that it would be "at least another sixty days . . . before I am able to issue a decision." The Board held the CO's statement was "insufficiently definite" under the Contract Disputes Act, which requires a CO to, within 60 days of receiving a certified claim over $100,000, either issue a decision or "notify the contractor of the time within which a decision will be issued."
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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.
Client Alert | 2 min read | 02.03.26
Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
Client Alert | 7 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
