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State Slammed For Adopting GAO Recommendation

Client Alert | less than 1 min read | 08.22.07

In Grunley Walsh Int'l v. U.S. (Fed. Cl. Aug. 3, 2007), in which Crowell & Moring represented the successful plaintiff, the Court of Federal Claims held that the Department of State acted arbitrarily when it adopted a GAO recommendation to reverse its own, longstanding interpretation of the total business volume requirement in the Diplomatic Construction Program statute (22 U.S.C. § 4852). The government argued that the court must defer to State's revised interpretation, but the Court refused to do so, because that would "effectively strip this court of any real review in any case where the agency followed a recommendation of the GAO on an interpretation of a statute or regulation."

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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

On January 26, 2026, the Centers for Medicare and Medicaid Services (CMS) circulated the Calendar Year (CY) 2027 Advance Notice to communicate proposed changes to Medicare Advantage (MA) capitation rates and Parts C and D payment policies.  The changes are expected to be finalized in April 2026 but may be delayed. The following is a summary of the most significant proposals, with further details below:...