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"Certain" Means No Weasel Words

Client Alert | less than 1 min read | 09.30.05

The Contract Disputes Act requires a contractor to specify a "sum certain" that it claims. The contractor in Sandoval Plumbing Repair, Inc. (ASBCA Sept. 14, 2005), specified a dollar amount but learned that by adding words such as "no less than" or "in excess of" before a specified amount makes the claim "uncertain" and requires dismissal.

Insights

Client Alert | 2 min read | 03.27.26

CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans

On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review....