For Whom Does the Appeal Clock Toll? Vitiation vs. Finality
Client Alert | less than 1 min read | 01.12.16
In Guardian Angels Med. Serv. Dogs Inc. v. U.S. (Jan. 8, 2016), the Federal Circuit held that a CO's request to evaluate additional information after a default termination "vitiated the finality" of the termination and reset the 12-month appeal clock, even though the CO neither received new information nor spent any time reconsidering her decision. Reversing the CFC's dismissal of the appeal as time-barred, the court held that, when a CO "evince[s] a clear willingness to consider additional evidence," the appeal period begins anew, rather than merely being suspended, and explained that "whether the contracting officer 'spends time' considering the request is not the proper standard."
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Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
