Stronger Dollar Pushes Trade Agreements Act Thresholds Down
Client Alert | less than 1 min read | 12.17.15
On December 15, 2015, the U.S. Trade Representative published its biennial readjustment of the Trade Agreements Act thresholds expressed in "special drawing rights." The new dollar thresholds, effective for 2016-2017, will be approximately 6.4% lower than the current thresholds, going to $191,000 for most covered supply contracts and $7,358,000 for most covered construction contracts, with other adjusted thresholds applicable to certain free trade agreements.
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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
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
