Compounding The Problem
Client Alert | 1 min read | 09.24.10
On September 22, 2010, the Civilian Agency Acquisition Council and Defense Acquisition Regulations Council issued a proposed rule that would amend the FAR to require compound, rather than simple, interest to be used in calculating damages for violations of the Truth in Negotiations Act (TINA). The proposal follows the problematic analysis in Gates v. Raytheon, 584 F.3d 1062 (Fed. Cir. 2009), which held that, because the Cost Accounting Standards (CAS) statute requires interest on cost impacts for CAS violations to be calculated at the rate established under 26 U.S.C. § 6621, the same rate referenced in the TINA statute, the interest must be compounded in accordance with 26 U.S.C. § 6622, even though the CAS statute does not refer to or incorporate § 6622 by reference.
Insights
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
