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Defense Contractors Begin To Feel Effect Of DoD Requirement To Provide Unique Item Identifiers And Unit Cost Information

Client Alert | less than 1 min read | 02.09.04

Many DoD contractors are recognizing the potential burden of a recent DoD clause compelling contractors to mark deliverable hardware valued in excess of $5,000 with a machine-readable, unique identification sufficient to last throughout the life of the hardware. The new DoD clause, included in solicitations issued starting January 1, 2004, can also require the same type of marking for subassemblies, components, and parts embedded within the hardware and further requires contractors to furnish the Government's unit acquisition cost, which in the case of fixed-price items is simply the unit price and in cost-type contracts is an estimate of the fully burdened unit cost at the time of delivery.

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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....