1. Home
  2. |Insights
  3. |Presolicitation Statements Not Dispositive Of Whether Mod Is Beyond Scope

Presolicitation Statements Not Dispositive Of Whether Mod Is Beyond Scope

Client Alert | less than 1 min read | 12.28.05

An agency's presolicitation statement that it did not initially intend a contract to include certain work did not bar the agency from later adding that work, according to the Court of Federal Claims in HDM Corp. v. United States (Dec. 14, 2005). Whether a contract was amended beyond its scope depends upon the breadth of the stated objectives of the solicitation, whether bidders were told that work could be added, and the nature of the added work, so early agency statements are not dispositive, the court held in this case successfully litigated by Crowell & Moring.

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....