Parent's No-Debarment Agreement Doesn't Stop CO Finding Sub Lacks Integrity
Client Alert | less than 1 min read | 08.21.08
In OSG Product Tankers, LLC v. U.S. (June 30, 2008), the Court of Federal Claims held that a CO could disqualify a contractor as not "presently responsible" due to lack of integrity because the contractor's parent had pled guilty to a number of felonies, despite an agency settlement agreement with the parent ruling out the parent's debarment as long as it complied with its plea agreement. According to the court, the debarment settlement involving the parent did not estop the CO's independent non-responsibility decision regarding the subsidiary, even though the lack of integrity finding was based on the actions of the parent.
Insights
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
