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Mandatory Display of Fraud Posters

Client Alert | less than 1 min read | 09.16.11

On September 16, 2011, DoD issued a final rule that requires contractors to prominently display in common work areas -- within business segments performing work on DoD contracts -- fraud hotline posters prepared by the DoD Office of the Inspector General, unless the contract is for the acquisition of a commercial item, will be performed entirely outside the United States, or does not exceed $5 million.  This requirement must be flowed down to all subcontracts that similarly qualify.

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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....