Disharmony in the Cyber Acquisition Patchwork
Client Alert | 1 min read | 05.07.15
While Executive Order No. 13636 asked for a review of "what steps can be taken to harmonize" existing cyber regulations governing federal acquisitions, a patchwork of more than a dozen different agency regulations – and dozens upon dozens of unpublished cyber policies – impose heavy burdens upon contractors seeking to build cost-effective cybersecurity compliance programs. On May 11, C&M's David Z. Bodenheimer will discuss this analysis and lead a co-sponsored program for the ABA Public Contract Law Section's Cybersecurity, Privacy, and Information Security Committee and the Science & Technology Law Section's Homeland Security Committee on "The Cybersecurity Patchwork of Federal Agency Rules & Unpublished Policies: How Do Contractors Comply?"
Insights
Client Alert | 2 min read | 02.03.26
CMS Doubles Down on RADV Audit Changes
On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025.
Client Alert | 2 min read | 02.03.26
Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
Client Alert | 7 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
