"Piggy-Backer" Falls at GAO
Client Alert | less than 1 min read | 06.01.05
In VSE Corp; Johnson Controls World Svs. Inc. (May 23, 2005 http://www.gao.gov/decisions/bidpro/2904523.pdf), GAO held that Johnson Controls could not circumvent GAO's strict timeliness rules by "piggy-backing" an untimely protest of a sole source award by the Department of Homeland Security onto a timely protest previously filed by VSE. Nonetheless, GAO found the sole source bridge construction contract was improper because DHS failed to prepare a required written justification and approval, and it expressly held that Johnson Controls, as well as VSE, must be given an opportunity to demonstrate an ability to satisfy DHS' requirement.
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Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
