GSA Proposes to Codify Override of Some Commercial Terms
Client Alert | 1 min read | 06.07.16
GSA issued a proposed rule to amend its acquisition regulation to make unenforceable certain common commercial supplier agreement (CSA) terms, a follow-up to the class deviation (discussed here) released last year. While some of the common commercial terms targeted arguably are, as GSA asserts, inconsistent or create ambiguity with federal law (e.g., provisions imposing non-federal law, arbitration provisions, and indemnification provisions), some likely are not (e.g., provisions giving precedence to government terms, placing restrictions on unilateral termination for breach, and requiring the contractor to provide the text of terms incorporated by reference).
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Client Alert | 4 min read | 09.26.25
Court Vacates CMS’s 2023 Final Rule on RADV Audits
On September 25, 2025, the Northern District of Texas granted plaintiffs’ motion for summary judgment in Humana v. Becerra, vacating CMS’s 2023 Final Rule regarding risk adjustment data validation (RADV) audits. In the litigation, Humana challenged CMS’s decision in the Final Rule to not continue applying a Fee-for-Service (FFS) adjuster to its RADV audit methodology.
Client Alert | 8 min read | 09.24.25
Client Alert | 14 min read | 09.24.25
The Middle East’s Big Bet on Artificial Intelligence and Data Security
Client Alert | 4 min read | 09.23.25
A Special Relationship Reboot? The US-UK Tech Prosperity Deal
