Final FAR Rule Limits Contractors’ Use Of Employee Confidentiality Agreements
Client Alert | 1 min read | 01.25.17
As of January 19, 2017, a new FAR Council Rule will prohibit federal dollars from going to companies that require employees or subcontractors to sign internal confidentiality agreements that restrict employees from reporting suspected waste, fraud, and abuse to the government; it will also require contractors to notify current employees and subcontractors that any existing confidentiality agreement inconsistent with this new Rule is no longer in effect. The Final Rule (discussed in greater detail here) was published in the Federal Register on January 13, 2017, and applies to all solicitations and contracts using fiscal year 2015 (and subsequent fiscal year) funds that do not already contain a comparable provision.
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Client Alert | 2 min read | 02.03.26
CMS Doubles Down on RADV Audit Changes
On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025.
Client Alert | 2 min read | 02.03.26
Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
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
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
