For Iraq War Items Sole Source Award, COFC Grants Limited Injunctive Relief Despite OCI And CICA Violations
Client Alert | 1 min read | 05.21.04
In Filtration Dev. Co. LLC v. U.S. (April 27, 2004), the Court of Federal Claims found (1) that a sole source award for filtration kits (to protect helicopters in Iraq from sand damage) that included a directed subcontract violated organizational conflict of interest (OCI) prohibitions because, even though it had performed no work on that system, the subcontractor held a Systems Engineering and Technical Assistance (SETA) contract for the system, and (2) that the urgent and compelling circumstances justification and approval (J&A) for the sole source action, despite explicitly authorizing procurement of a larger number of kits than already ordered by the prime from the designated subcontractor, was limited by the scope of the current emergency to the smaller order already placed. The court granted injunctive relief, but only to preclude further contracts or orders without a new J&A, and declined to enjoin the government from including the directed subcontractor in future competitions or contracting actions because, inter alia, the OCI could be waived.
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.
Client Alert | 4 min read | 03.25.26
NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know
Client Alert | 11 min read | 03.25.26
White House National AI Policy Framework Calls for Preempting State Laws, Protecting Children
Client Alert | 3 min read | 03.24.26
California Considering A Massive Expansion of Its Antitrust Laws
