Proposed DFARS Rule to Provide Guidance on Assessing Commercial Price Reasonableness
Client Alert | less than 1 min read | 08.05.15
On August 3, the DoD issued a proposed rule, with comments due by October 2, to amend the DFARS to clarify the amount and types of data that contracting officers may require from contractors in order to perform price reasonableness assessments for commercial items. The proposed rule addresses (1) the conditions under which prior sales information is sufficient, (2) when "uncertified cost data" will be required and the required format, and (3) the limits on requiring additional cost information when there are "sufficient nongovernment sales to establish reasonableness of price."
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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.
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Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
