What The Far Council Giveth The Dar Council Taketh Away
Client Alert | 1 min read | 12.20.06
After several years of consideration, the FAR and DAR Councils published three related sets of regulations in the Federal Register on December 12, 2006, addressing controversial issues about time and material (T&M) and Labor Hour (LH) contracts (see notice on left about upcoming webinar on these regulations). The FAR Council published two final rules permitting competitively awarded contracts for commercial items to qualify as commercial item contracts (with important limitations, including unprecedented rights to interview employees as part of a standard audit) and permitting contractors to bill for work performed by subcontractors on T&M/LH contracts in one of three ways (leaving it to each individual agency to decide which method to permit on the agency’s contracts), while the DAR Council published an interim rule adopting the method of billing subcontractor labor that is likely to be least attractive to industry.
Insights
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans
On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review.
Client Alert | 4 min read | 03.25.26
NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know
Client Alert | 11 min read | 03.25.26
White House National AI Policy Framework Calls for Preempting State Laws, Protecting Children
Client Alert | 3 min read | 03.24.26
California Considering A Massive Expansion of Its Antitrust Laws
