Congress Enacts Appropriations Restriction Relating to Felony Convictions
Client Alert | 1 min read | 01.18.12
As is discussed in more detail in a blog posting, the recently enacted Consolidated Appropriations Act of 2012 includes provision in five of the nine individual bills covered in the Act prohibiting the use of funds “to enter into a contract, memorandum of understanding, or cooperative agreement with, make a grant to, or provide a loan or loan guarantee to, any corporation” with a felony conviction within the preceding 24 months, unless the agency has considered suspension or debarment and made a determination that no further action is necessary. This provision is almost sure to create uncertainty because Congress did not create a uniform standard, but instead included language in only certain individual appropriation acts, with substantial variances between the different provisions (e.g., some provisions only apply if the corporation is convicted while other also include officers or agents of the corporation).
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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
