Interim Rule Eliminates CO Pricing Review of Indirect Offset Costs
Client Alert | less than 1 min read | 06.02.15
Today, DoD issued an interim rule immediately relieving contracting officers (COs) of responsibility for performing a price reasonableness analysis of the costs associated with indirect offsets when mandated by a foreign government customer under a Foreign Military Sales (FMS) contract. The revised rule responds to a "foreseeable trend of increasing numbers and complexity of indirect offsets" on which FMS customers insist and reflects a desire to relieve COs of the burden of performing this analysis when no DoD-appropriated funds are used and when COs have limited ability to evaluate the indirect offset effort in any event.
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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
