New Executive Compensation Limits
Client Alert | 1 min read | 06.28.13
On June 26, 2013, the government issued an interim rule that purports to expand the application of the executive compensation benchmark, currently set at $763,029, from senior executives to all contractor employees performing on contracts awarded as of December 31, 2011, by DoD, NASA, and the Coast Guard. As discussed in our blog posting, this interim rule, which is effective immediately, is intended to make any compensation costs incurred after January 1, 2012, over the benchmark amount unallowable for contracts subject to the FAR cost principles, but challenges to this rule based on the terms of the Allowable Cost and Payment clause might result.
Insights
Client Alert | 2 min read | 02.03.26
CMS Doubles Down on RADV Audit Changes
On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025.
Client Alert | 2 min read | 02.03.26
Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
Client Alert | 7 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
