PODCAST: Court Limits EPA’s Ability to Delay Clean Air Act Regulation Without Rulemaking — C&M's Trump: The First Year Series
Client Alert | 1 min read | 07.06.17
In the latest podcast for Crowell & Moring’s “Trump: The First Year” series, Dan Wolff and Tom Lorenzen, both litigation partners in the firm’s Environment & Natural Resources Group and Administrative Law & Regulatory Practice, discuss the implications of a July 3 D.C. Circuit ruling invalidating EPA's 90-day administrative stay of the current oil and gas methane rule.
Discussed in this 21-minute podcast:
- An overview of the Clean Air Council v. Pruitt decision.
- The possible impacts of this decision on the administration’s stated goal of "deconstructing the administrative state."
- Other possible mechanisms for halting rules in the short term without going through notice-and-comment rulemaking.
- The practical implications of this ruling, and key takeaways for businesses.
Click below to listen or access from one of these links:
PodBean | SoundCloud | iTunes
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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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