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Pre-Award Protest Timeliness Rule Extended

Client Alert | less than 1 min read | 12.18.12

In Comint Sys. Corp. v. U.S. (Dec. 7, 2012), the Federal Circuit extended its judicially imposed timeliness rules to require a protest of a solicitation defect to be filed in court prior to award, if practical, even if the alleged error occurred after proposals had been submitted. The court noted that this is consistent with the GAO timeliness rules.


Insights

Client Alert | 2 min read | 03.27.26

CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans

On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review....