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Don't Risk A "Jury Verdict"

Client Alert | less than 1 min read | 03.12.10

The ASBCA decision in States Roofing Corp. (Jan. 19, 2010) reminds us that contemporaneously tracking the costs of preparing and negotiating REAs can be critical to recovering them from the government as contract administration costs. The ASBCA found that the contractor's REA proposal efforts included in-house labor, legal, and accounting costs that were properly classified as contract administration costs, but found inter alia that personnel did not track those efforts separately from other contract work and the contractor's post-hoc allocations were unreliable - leading the ASBCA to use a "jury verdict" approach and award less than 12% of the contractor's claim.

Insights

Client Alert | 8 min read | 04.17.26

CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors

On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements....