Unanimous Supreme Court Cabins Wartime Suspension of Limitations Act
Client Alert | 1 min read | 05.27.15
The Supreme Court on Tuesday handed down KBR v. U.S. ex rel. Carter, in which it unanimously reversed the Fourth Circuit's interpretation of the Wartime Suspension of Limitations Act, whose text, structure, and history all show it to be limited to criminal offenses—it does not toll the statute of limitations on civil FCA cases. The Court also unanimously affirmed the Fourth Circuit's interpretation of the FCA's first-to-file bar, and thus resolved a split with the D.C. Circuit, by holding that a qui tam complaint that has been dismissed is no longer "pending" within the meaning of the bar and, therefore, will not preclude future, related actions.
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Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
