Final Rule on Nondisplacement of Workers Performing Service Contracts
Client Alert | less than 1 min read | 01.03.13
On December 21, 2012, the government issued a final rule that requires incoming contractors to offer qualified employees of the predecessor contractor and its subcontractors a right of first refusal of employment if the positions are covered by the Service Contract Act, unless a waiver is obtained or an exception applies. The rule, which is effective January 18, 2013, implements Executive Order 13495 and the Labor Department's regulations on Nondisplacement of Qualified Workers Under Service Contracts.
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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.
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Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
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CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
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Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
