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LOC Clause Applies To Each Delivery Order, Not Full Contract

Client Alert | 1 min read | 07.30.04

In Analysas Corp. (May 12, 2004), the ASBCA held that, under an indefinite quantity cost-plus-fixed-fee contract for services, the contract’s limitation of cost (“LOC”) clause (which required the contractor to give notice if its costs were expected to exceed 75% of the "estimated cost specified in the Schedule") allowed the government to deny payments to a contractor for costs it incurred in excess of the estimated cost for each delivery order, even though the contractor had not yet exceeded 75% of the maximum total labor hours specified "in the Schedule" for the full contract. The Board reasoned that the contract lacked the “critical provision” of a specific dollar figure "in the Schedule" for the total estimated contract cost, instead allowing for later addition of estimated costs for each delivery order that the government issued.

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Client Alert | 2 min read | 03.27.26

CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans

On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review....

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