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NIST Finalizes Enhanced Security Requirements for Combating Advanced Cyber Threats

Client Alert | 1 min read | 02.09.21

The National Institute of Standards and Technology (NIST) recently released the final version of NIST Special Publication (SP) 800-172, Enhanced Security Requirements for Protecting Controlled Unclassified Information. Designed to supplement the requirements in NIST SP 800-171—the applicable standard under DFARS 252.204-7012—800-172 provides 35 enhanced security requirements to protect controlled unclassified information (CUI) associated with critical programs and high value assets from sophisticated adversaries referred to as advanced persistent threats (APTs).

Although expected to impact relatively few contractors, where applicable, agencies may include select enhanced security requirements from 800-172 in their contract provisions. The Department of Defense (DoD) has also incorporated several of the requirements identified in prior drafts of 800-172 into maturity levels 4 and 5 of the Cybersecurity Maturity Model Certification (CMMC).

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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....