DCAA "Independence"
Client Alert | 1 min read | 03.24.09
The Defense Contract Audit Agency (DCAA) has revised its policy concerning "unsatisfactory conditions related to actions of Government Officials" to provide that "significant and serious" disagreements with actions by government officials, including contracting officers, will be reported directly to the Inspector General rather than to the Government official's management chain, as had been the policy in the past (Mar. 13, 2009). Prior guidance had already required direct reporting of "suspected irregularities" such as criminal violations, and this guidance appears to be intended to cover discretionary decisions that the auditors believe will "result in substantial harm to the Government or taxpayers, or that frustrate public policy."
Insights
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
