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Substantial Changes To CAS Administration Regulations

Client Alert | 1 min read | 03.16.05

Final rules, effective April 8, 2005, concerning proposed changes to CAS administration requirements that have been pending since April 2000 were promulgated on March 9, 2005 (70 Fed. Reg. 11743-61). The new regulations will be discussed in detail at the upcoming OOPS/WOOPS programs on March 31-April 1/April 14-15, but some of the highlights include:

  • When there is a CAS noncompliance, contract price adjustments may be required for closed contracts and closed years,
  • Improvement in the definition of "desirable" and "required" changes may permit contractors to avoid price adjustments,
  • Retroactive accounting changes are permitted in limited circumstances,
  • Widely criticized proposals to prohibit offsets between FFP and flexibly-priced contracts were abandoned, and
  • Estimates to complete rather than original cost estimates must be used to determine cost impact on FFP contracts.

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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....

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