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Interim Rule Eliminates CO Pricing Review of Indirect Offset Costs

Client Alert | less than 1 min read | 06.02.15

Today, DoD issued an interim rule immediately relieving contracting officers (COs) of responsibility for performing a price reasonableness analysis of the costs associated with indirect offsets when mandated by a foreign government customer under a Foreign Military Sales (FMS) contract. The revised rule responds to a "foreseeable trend of increasing numbers and complexity of indirect offsets" on which FMS customers insist and reflects a desire to relieve COs of the burden of performing this analysis when no DoD-appropriated funds are used and when COs have limited ability to evaluate the indirect offset effort in any event.

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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

On January 26, 2026, the Centers for Medicare and Medicaid Services (CMS) circulated the Calendar Year (CY) 2027 Advance Notice to communicate proposed changes to Medicare Advantage (MA) capitation rates and Parts C and D payment policies.  The changes are expected to be finalized in April 2026 but may be delayed. The following is a summary of the most significant proposals, with further details below:...