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CFC’s Transfer to CBCA Not Constrained by Board’s 90-Day Appeal Period

Client Alert | 1 min read | 10.06.16

In Appeal of Suffolk Constr. Co., the CBCA accepted the transfer of an appeal from the CFC to the CBCA, where the contractor had several pending appeals relating to the same contract, despite the fact that the CFC appeal was not filed within CBCA’s 90-day appeal period after the final decision. GSA argued that the CBCA lacked jurisdiction because it was filed after the 90 days had run (but before the CFC’s one-year appeal period), but the board held that – when “2 or more actions aris[e] from one contract” – the requirement for initiating a timely board appeal did not constrain the CFC’s authority to transfer to the board an action over which the CFC concededly had jurisdiction.

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Client Alert | 10 min read | 07.08.26

Proactive Compliance in Health Care: “Getting Ahead” of Enforcement in 2026 and Beyond

As federal and state regulators alike continue to tout holding health care organizations accountable for alleged fraud, waste, and abuse as a top priority, ensuring compliance and minimizing enforcement risk has never been more imperative — or more challenging. Health care organizations operate at the intersection of rapid technological changes and within an increasingly complex regulatory landscape, where the rules governing scrutinized areas such as privacy, AI, billing integrity, and strategic transactions are being written, rewritten, and enforced in real time. Treating compliance as a periodic documentation exercise is simply not an option. Today, an effective risk mitigation strategy must be grounded in two complementary elements: a thorough understanding of evolving regulatory obligations and a candid internal assessment of potential points of exposure....

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