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CAS Exemption For Time & Material And Labor Hour Contracts

Client Alert | less than 1 min read | 07.06.07

To conform the Cost Accounting Standards regulations to the statutory provisions of the Services Acquisition Reform Act and to the recently amended provisions of the FAR, the CAS Board has issued regulations (72 Fed. Reg. 36367, July 3, 2007) exempting Time and Material (T&M) and Labor Hour (LH) contracts for commercial items from CAS coverage. Because the comparable FAR provisions require competition as a prerequisite to award of T&M and LH contracts for commercial items, the CAS exemption will apply only to competitively awarded contracts.

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....