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Contracting Officer's Final Decision Not Afforded RES Judicata Status

Client Alert | less than 1 min read | 05.10.04

In Roxco, Ltd. v. United States (Mar. 29, 2004), the COFC, among other things, rejected the Air Force's argument that Roxco's equitable adjustment claims, which were submitted more than a year after the Contracting Officer's default termination decision, should be barred through the application of res judicata, even if, as the Air Force asserted, those claims could have been raised as defenses to the default termination. The COFC reasoned that an extension of res judicata to contracting officers' final decisions would contradict the Contract Disputes Act's six-year statutory time limit for filing claims.

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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....