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DoD's Proposed Counterfeit Electronic Parts Rules Are Short on Details

Client Alert | 1 min read | 05.22.13

Following up on its publication of an instruction on counterfeit parts on May 16, DoD issued a long-expected proposed rule on counterfeit electronic parts avoidance, detection, and liability, with comments due by July 15. As discussed on our blog, the rule -- which applies only to CAS-covered prime contractors but will have a much broader impact on subcontractors and suppliers -- requires that business systems include DoD-approved avoidance and detection systems, but leaves the details of the newly required systems to be fleshed out, it would seem, by DCAA and/or DCMA, and, while it imposes potentially unlimited liability for counterfeit parts, it has an exceedingly narrow "safe harbor." 


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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

On January 26, 2026, the Centers for Medicare and Medicaid Services (CMS) circulated the Calendar Year (CY) 2027 Advance Notice to communicate proposed changes to Medicare Advantage (MA) capitation rates and Parts C and D payment policies.  The changes are expected to be finalized in April 2026 but may be delayed. The following is a summary of the most significant proposals, with further details below:...