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Don't Want a Setoff? Better Say It

Client Alert | less than 1 min read | 07.13.10

In Global Ship Sys., Inc. v Dept. of Homeland Sec'y (CBCA June 25, 2010), the board held that a settlement payment owed by the government could be offset against a debt owed by the contractor on a separate contract, even though the settlement agreement expressly required the CO to "request" that the payment be made to Global's designated bank account. More explicit language is required to overcome the government's general right of offset.

Insights

Client Alert | 2 min read | 03.27.26

CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans

On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review....