Small Biz Get An Extra Two Years for Revenue Lookback
Client Alert | 1 min read | 12.20.18
On December 17, 2018, President Trump signed into law H.R. 6330, Small Business Runway Extension Act of 2018, which amends the Small Business Act to extend the time period over which the size standard is measured for business concerns providing services. Whereas previously the Small Business Act used the annual average receipts over a three-year period to determine size for services contracts, size for services contracts will now be measured by the annual average receipts over a five-year period. The act does not amend any revenue limits or impact size standards for manufacturing contracts which are based on employee count. While the change to the act is effective immediately, the Small Business Administration has yet to implement the corresponding changes to its regulations and we expect them to do so shortly.
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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 | 2 min read | 02.03.26
Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
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
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Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
