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FEMA to Release New Emergency Management Priorities and Allocation System to Govern FEMA DPA Title I Activities

Client Alert | 1 min read | 05.12.20

On May 13, 2020, the Federal Emergency Management Agency (FEMA) will publish an interim final rule establishing the Emergency Management Priorities and Allocation System (EMPAS) pursuant to Title I of the Defense Production Act (DPA). As drafted, EMPAS will apply beyond the current COVID-19 context and will become part of the Federal Priority and Allocations System (which includes, for example, the Defense Priorities and Allocation System (DPAS) and the Health Resources Priority and Allocations System (HRPAS)). Although largely similar to the DPAS and HRPAS, EMPAS also provides express authorization to issue rated orders to facilitate sales of health and medical resources to third parties while simultaneously rejecting any government financial liability for such orders (44 C.F.R. § 333.12(c) and 333.19). EMPAS is effective immediately upon publication, and comments on the interim final rule will be accepted through June 12, 2020.

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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:...