No Buyer's Remorse – ASBCA Orders Air Force to Pay for What It Got
Client Alert | 1 min read | 10.09.15
In Honeywell Int'l, Inc. (Sept. 24, 2015), the ASBCA held that the Air Force must pay for two solar arrays that the contractor (represented by C&M) provided under an Energy Savings Performance Contract, even though the Board had earlier determined that certain of the contract's payment terms were "invalid." In finding the Air Force liable under an implied-in-fact contract theory, the Board rejected arguments that the Air Force had never intended to acquire the solar arrays and that the contracting officers had lacked authority to bind the government, explaining that the Air Force, simply by refusing to accept them, could not escape liability for the arrays that were "supplied … as designed, completed on time, and installed as required."
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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
