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GAO Finds "Classic Example" Of Impaired Objectivity OCI

Client Alert | less than 1 min read | 09.10.04

In PURVIS Systems, Inc. (Aug. 16, 2004), GAO held that the Navy failed reasonably to consider or evaluate potential organizational conflicts of interest ("OCI") created by the awardee's role in evaluating performance of undersea warfare systems that have been manufactured either by the awardee or its competitors. GAO rejected the awardee's contention that no OCI issues could be created by the awardee's evaluation of the systems because such work was not "part of the procurement process" and explained that the situation presented a "classic example" of an "impaired objectivity" OCI.

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Client Alert | 4 min read | 09.16.26

CMS Offers Guidance as Scrutiny Rises Over ABA Therapy in Medicaid

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021. ...