Limitations Of Cost Notice Obligations Must Be Met
Client Alert | less than 1 min read | 09.15.06
The ASBCA in International Technology Corp. (July 17, 2006), denied a claim for an upward adjustment above the contract's cost limitation because the contractor had inexcusably failed to comply with the Limitation of Cost clause provision requiring advance notice to the government of the projected costs over the limit. The board rejected the contractor's argument that it had to determine the allowability of its subcontractor's costs prior to providing notice, finding that notice is required when a contractor has “reason to believe” there will be a cost increase.
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.
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Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
