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New Treasury Guidance Provides Relief from Financial Instrument Offering under Payroll Support Program for Small and Mid-Sized Aviation Businesses

Client Alert | 1 min read | 04.14.20

Treasury recently announced additional guidance regarding the Payroll Support Program under Title IV of the CARES Act, which provides payroll support for American workers employed by passenger air carriers, cargo air carriers, and certain contractors to Part 121 air carriers. This guidance modifies Treasury's earlier requirement that applicants offer warrants, options, preferred stock, debt securities, notes, or other financial instruments as compensation for the provision of payroll support. 

Recognizing the difficulty that small and mid-sized aviation businesses face in making such an offer, Treasury decided that it will not require passenger air carriers that receive $100 million or less in payroll assistance to provide financial instruments as appropriate compensation. Because Treasury will not need to evaluate financial instruments proposed by passenger air carriers qualifying for this exception, funds will be available to those air carriers promptly upon approval of their applications.

This exception does not apply to passenger air carriers whose allocated payments would exceed $100 million, or to cargo carriers or contractors. Treasury is expected to provide further guidance for those applicants in the near future. Additional guidance about this program can be found in our previous client alert.

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Client Alert | 2 min read | 03.27.26

CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans

On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review....