Federal Circuit Extends 'Good Faith' Shield of Agencies
Client Alert | less than 1 min read | 08.12.13
In Croman Corp. v. U.S. (July 31, 2013), the Federal Circuit upheld the reasonableness of an agency's corrective action after expanding the protestor's argument into a "bad faith" allegation. When the protestor complained that the cancellation of several CLINs was without a rational basis and put forward evidence that indicated the agency's rationale was pretextual, instead of requiring the agency to put forward proof to support its stated rationale, the court relabeled the challenge as a "bad faith" allegation, which it held the protestor had not shown by clear and convincing evidence.
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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.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
