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Significant Revisions to Non-U.S. Content Disclosure and Financing Policies Proposed

Client Alert | less than 1 min read | 10.07.15

The Defense Security Cooperation Agency has informally circulated draft revisions to the August 2009 Guidelines for Foreign Military Financing of Direct Commercial Contracts, which would elaborate on, and in a number of instances significantly change, its policies with respect to the disclosure and financing of U.S., non-U.S., and now "host country" content. Please contact us if you would like to obtain a copy of the draft and/or participate in commenting on the proposal by the due date of November 16, 2015.


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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....