OMB Releases Final Federal Source Code Policy
Client Alert | 1 min read | 08.12.16
On August 8, 2016, OMB released the final federal source code policy, which requires new, custom-made source code developed specifically by or for the federal government to be made available for sharing and reuse across all federal agencies in an effort to minimize duplicative procurements and reduce federal vendor lock-in. The policy also establishes a pilot program that requires agencies commissioning new, custom software to release at least 20 percent of that code as open source software (OSS) for three years, which will require agencies to consider the value of publishing custom code as OSS and negotiate data rights reflective of its value, as well as to obtain sufficient rights to fulfill the policy’s objectives.
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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
