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SBA Proposes Fundamental Revision to Subcontract Reporting

Client Alert | less than 1 min read | 10.08.15

On October 6, 2015, the SBA issued a proposed rule to change the way prime contractors report how they complied with individual subcontracting plan goals by allowing primes to receive credit for awards made at any subcontracting tier (instead of first-tier only). As part of this proposed change, primes would have to incorporate the subcontracting plan goals of their lower-tier subcontractors into their individual subcontracting plans and would become responsible for ensuring that subcontractors adopt and comply with their plans.


Insights

Client Alert | 4 min read | 09.26.25

Court Vacates CMS’s 2023 Final Rule on RADV Audits

On September 25, 2025, the Northern District of Texas granted plaintiffs’ motion for summary judgment in Humana v. Becerra, vacating CMS’s 2023 Final Rule regarding risk adjustment data validation (RADV) audits. In the litigation, Humana challenged CMS’s decision in the Final Rule to not continue applying a Fee-for-Service (FFS) adjuster to its RADV audit methodology....