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On Time Means On Time

Client Alert | less than 1 min read | 11.09.06

Late is late, even if only by 2 minutes, according to the GAO in Omega Systems, Inc. (Nov. 6, 2006, http://www.gao.gov/decisions/bidpro/298767.pdf), denying a protest challenging the Marine Corps' refusal to consider an offeror's late final proposal revision. Although the protester claimed its late proposal revision was acceptable because it was a modification to an "otherwise successful proposal that makes its terms more favorable to the government," the GAO held that an otherwise successful proposal is one that "would result in the award of the contract to the offeror regardless of the late modification," and here the protester's price without the revision was too high to win.

Insights

Client Alert | 6 min read | 06.11.26

CMS Announces New Medicaid Eligibility Requirements: Implications for Managed Care Plans

On Wednesday, June 3, 2026, the Department of Health and Human Services (HHS) published an interim final rule with comment (IFC) instructing all state Medicaid agencies to incorporate “community engagement” as an eligibility condition for program participation by no later than January 1, 2027. The rule (Medicaid Program; Community Engagement Requirement for Certain Individuals) does not impose affirmative operational obligations for Medicaid managed care plans, as it focuses primarily on equipping the states to administer the community engagement requirement. However, it does establish a few specific guardrails to govern the role managed care organizations, prepaid inpatient health plans, and prepaid ambulatory health plans may — and may not — play in that administration....