It’s Time for a Raise! DoD Proposes to Increase CPSR Threshold
Client Alert | 1 min read | 06.11.19
On May 31, 2019, DoD issued a proposed rule, which would amend the Defense Acquisition Regulation Supplement (DFARS) to establish a DoD-specific Contractor Purchasing System Review (CPSR) threshold of $50M at DFARS 244.302, to be used in lieu of $25M threshold at FAR 44.302(a), which has remained unchanged since 1996. According to the Federal Register, it is estimated that, with this new threshold in place, DCMA ACOs can reduce the number of contractor reviews by approximately 20% (from around 667 to 534), which would reduce the burden on smaller contractors and allow a more efficient and effective use of CPSR resources to review larger contractors where more taxpayer dollars are at risk. Comments on the rule are due by July 30, 2019.
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Client Alert | 2 min read | 02.03.26
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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.
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Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
