Potential OCI Short-Circuits Sole-Source Award
Client Alert | less than 1 min read | 01.17.08
In Superlative Technologies, Inc. (Jan. 4, 2008, http://www.gao.gov/decisions/bidpro/310489.pdf), GAO held improper the cancellation of a solicitation by DOJ due to potential Procurement Integrity Act (PIA) and organizational conflict of interest unfair competitive advantage problems when DOJ turned around and awarded a sole-source contract for the same work to a contractor using as a subcontractor the company with the PIA/OCI problem. GAO recommended that DOJ reopen the competition and follow the procurement integrity and OCI regulations to determine the scope of the problem and whether any offerors should be disqualified or other corrective actions should be required.
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
