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It’s Back – DCAA’s Non-Defense Audit Authority Revived

Client Alert | less than 1 min read | 11.03.16

A recent DCAA policy memorandum lifted the moratorium on DCAA performing non-Defense audits, which (as discussed here) effectively applied only to incurred cost audits. Specifically, because DCAA has purportedly "met the requirement of less than 18 months of incurred cost inventory" outlined in the 2016 National Defense Authorization Act as of October 1, 2016, DCAA "may again provide full audit support for non-Defense agencies" and the Operations Directorate "has coordinated at the Executive level with [its] reimbursable customers to inform them that [its] audit services can resume."

Insights

Client Alert | 4 min read | 11.09.26

CMS Finalizes Its 2026 Organ Procurement Organization Rule

On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions: ...