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Relying on a Parent's Experience and Resources in Your Proposal? Some Explanation Required

Client Alert | less than 1 min read | 01.21.16

In Deloitte Consulting, LLP (Nov. 16, 2015), GAO disapproved of the agency crediting a subsidiary with the experience of its corporate parent when the subsidiary's proposal said little more than it receives substantial support from the parent and did not identify which resources and experiences related to which entity. GAO also ruled that, merely because the corporate parent novated to its subsidiary the Federal Supply Schedule contract and blanket purchase agreement under which the contract was awarded, it did not mean that the subsidiary "successor in interest" necessarily had the same resources or experience as its predecessor.

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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....