Don't Assume That A Debriefing Is Continuing After The Initial Session
Client Alert | less than 1 min read | 05.25.05
In New SI, LLC (Nov. 22, 2004, http://www.gao.gov/decisions/bidpro/295209.htm), GAO concluded that a protest was untimely filed when the contractor waited until after it had received agency responses to the contractor's additional questions submitted at the invitation of the Contracting Officer in the course of the initial debriefing session. In response to the contractor's argument that the debriefing was continuing and not concluded until after the agency's response to questions, GAO explained that, “absent affirmative indication from the agency that the debriefing would remain open after the scheduled session, we consider [the debriefing] to have concluded at the end of that [initial] session.”
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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.
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