International Trade Bulletin - Volume 1, Issue 12
Client Alert | 1 min read | 08.22.06
Inside this issue:
- EUROPE IN THE SPOTLIGHT
- EXPORT CONTROL IN THE SPOTLIGHT
- SECTION 337: Today's Trade Remedy of Choice?
- RUSSIA: Will Nonproliferation Sanctions on Russian Companies Draw Retaliation?
- ANTI-DUMPING: WTO Closes Door on U.S. Zeroing Practice
- CUSTOMS: The U.S. has announced its decision to appeal the recent WTO ruling concerning non-uniform application of the EU's customs administration
- AVIATION: U.S. and EU Renew their Commitment to Open Skies After DOT Delays Its Controversial Foreign Control Rule
- MARKET ACCESS: After Doha : Practical Approaches for Cutting the Costs of Trade
Contacts
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


