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CAS Board Adjusts Coverage Threshold

Client Alert | less than 1 min read | 06.14.07

The Cost Accounting Standards Board issued a final rule, effective June 14, 2007, adjusting the $500,000 threshold for contract coverage upward to $650,000 to be consistent with the threshold in the Truth in Negotiations Act (72 Fed. Reg. 32809). Apparently in response to comments from the Project on Government Oversight (POGO), the final rule (unlike the proposed rule published on December 15, 2005) does not increase the other CAS thresholds – such as the $7.5M “trigger” contract threshold and the $50M threshold for “full” CAS coverage and submission of a Disclosure Statement – because the CAS Board has determined that these are not “acquisition-related dollar thresholds” required to be adjusted for inflation under the FY05 Defense Authorization Act.

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Client Alert | 4 min read | 09.16.26

CMS Offers Guidance as Scrutiny Rises Over ABA Therapy in Medicaid

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021. ...