Do the Exclusion Archives on SAM.gov Violate Contractors' Liberty Interest?
Client Alert | less than 1 min read | 09.29.16
The suspension and debarment remedies are not meant to punish contractors for past misdeeds, yet information about past exclusions is stored indefinitely on the SAM.gov website, and this information is increasingly causing collateral consequences outside the government marketplace. In an article published in Bloomberg BNA, C&M attorneys discuss the evolution of the excluded parties list and explore how a contractor might challenge the exclusion archives as a violation of a contractor’s constitutional liberty interests.
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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.
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Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements


