Relying on a Parent's Experience and Resources in Your Proposal? Some Explanation Required
Client Alert | less than 1 min read | 01.21.16
In Deloitte Consulting, LLP (Nov. 16, 2015), GAO disapproved of the agency crediting a subsidiary with the experience of its corporate parent when the subsidiary's proposal said little more than it receives substantial support from the parent and did not identify which resources and experiences related to which entity. GAO also ruled that, merely because the corporate parent novated to its subsidiary the Federal Supply Schedule contract and blanket purchase agreement under which the contract was awarded, it did not mean that the subsidiary "successor in interest" necessarily had the same resources or experience as its predecessor.
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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.
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
Client Alert | 9 min read | 01.30.26
