"Meaningful Consideration" of Procurement's Primary Activity Required in Size Standard Determinations
Client Alert | 1 min read | 10.16.14
In RLB Contracting, Inc. v. U.S. (Oct. 3, 2014), the Court of Federal Claims enjoined the USDA from moving forward with a small business set-aside procurement for a shoreline and marsh restoration project issued under a NAICS code for "Other Heavy and Civil Engineering Construction," to which both the USDA and SBA found the code’s smaller size standard exception for "contracts which are comprised primarily of dredging and surface clean up" inapplicable. Concluding that the size standard decision by the USDA (which was affirmed by the SBA) was "flawed because the [administrative] record does not show that they gave proper consideration to whether dredging constitutes the primary activity involved," the CFC deemed the size standard determination "irrational."
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Client Alert | 4 min read | 09.26.25
Court Vacates CMS’s 2023 Final Rule on RADV Audits
On September 25, 2025, the Northern District of Texas granted plaintiffs’ motion for summary judgment in Humana v. Becerra, vacating CMS’s 2023 Final Rule regarding risk adjustment data validation (RADV) audits. In the litigation, Humana challenged CMS’s decision in the Final Rule to not continue applying a Fee-for-Service (FFS) adjuster to its RADV audit methodology.
Client Alert | 8 min read | 09.24.25
Client Alert | 14 min read | 09.24.25
The Middle East’s Big Bet on Artificial Intelligence and Data Security
Client Alert | 4 min read | 09.23.25
A Special Relationship Reboot? The US-UK Tech Prosperity Deal
