Flawed Pension Cost Decision Is Reversed - But Why?
Client Alert | less than 1 min read | 05.20.08
Last year, the ASBCA held in Raytheon Corp., ASBCA No. 54907, 07-2 BCA 33,655, that contractors are noncompliant with CAS requirements if they do not complete the segment closing adjustment required by CAS 413 for pension costs within the same fiscal year as the segment closing and determined that the interest due on CAS noncompliances is subject to compounding daily. On April 30, 2008, the Board reversed that decision on reconsideration, holding, without explanation, that the Government could not have suffered any damage as a result of the so-called noncompliance, making its prior holding about the calculation of interest moot and, therefore, dicta.
Insights
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
