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FAR Amended to Standardize Past Performance Evaluations

Client Alert | less than 1 min read | 08.05.13

On August 1, 2013, the FAR was amended to provide for standardized past performance evaluation factors and performance rating categories for use government-wide and to require that past performance information be entered into the Contractor Performance Assessment Reporting System (CPARS). The final rule, which becomes effective on September 3, 2013, leaves intact the existing process to appeal an evaluation and places an emphasis on monitoring the quality and timeliness of submission of past performance information.


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Client Alert | 5 min read | 04.23.26

CMS Proposes New Payment Policy for IOPOs and HCLs

In keeping with ongoing efforts to intensify regulatory oversight of organ procurement organizations (OPOs) and curtail improper spending within federal health programs, the Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would, among other adjustments, align Medicare payment policies for non-renal organs to be consistent with those currently applicable to kidneys. If enacted as drafted, this latest rule could have a direct impact on the financial stability of OPOs and histocompatibility laboratories (HCL) at a time when such organizations face increasing pressure to meet CMS’s new outcome measures — or else face non-renewal or decertification later this year. ...