Idle Your Engines: Feds Instruct Agencies to Stand Down on "Fair Pay and Safe Workplaces"
Client Alert | 1 min read | 10.26.16
On October 25, OFPP issued a Memorandum for Chief Acquisition Officers instructing agencies to refrain from implementing the “Fair Pay and Safe Workplaces” final rule (which was enjoined by a federal court on October 25, as discussed here) and ensure that “new solicitations do not include representations or clauses that the enjoined coverage of the rule would have required” and that, “[i]f a solicitation has been issued with [the] representations or clauses …, amend those solicitations immediately to remove” them. The memorandum also states that GSA has “halted actions to release the changes for the System for Award Management (SAM) that would support bidder and contractor submission of information on labor law violation decisions” and those that “would support public disclosure of this information in the Federal Awardee Performance and Integrity Information System (FAPIIS).”
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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 | 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
Client Alert | 9 min read | 01.30.26
