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CAS Offsets Permitted Among Different Contract Types

Client Alert | less than 1 min read | 04.14.06

In an important case of first impression, the Court of Federal Claims in Lockheed Martin Corp. v. United States (Mar. 29, 2006) has held that the cost impact of a Cost Accounting Standard (CAS) noncompliance is the net of all increased costs and all decreased costs that result from the noncompliance on all CAS-covered contracts. The Court rejected the government's argument that decreased costs paid on fixed-price contracts could not be offset against increased costs paid on cost-reimbursement contracts, finding that it "is -- in a word -- wrong."

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Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....