Myth-Busting is Still Alive: FAR Council Encourages Industry/Government Communications
Client Alert | 1 min read | 12.02.16
To implement section 887 of the FY 2016 National Defense Authorization Act, the FAR Council, on November 29, proposed a rule to amend FAR 1.102-2 by adding language to clarify that the government may, and is encouraged to, communicate with industry as part of market research, if such exchanges comport with existing law and regulations and do not further an unfair competitive advantage. Continuing the conversation that the 2011 and 2012 Office of Federal Procurement Policy Myth-Busting memoranda commenced, the Council also requested suggestions about ways to “further enhance open communication between industry and the Federal acquisition community[,]” as well as information responding to specific questions – responses to which are due on or before January 30, 2017 (the same due date for submitting comments on the proposed rule).
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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.
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
