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The Confusing World of Compensation Caps

Client Alert | less than 1 min read | 01.13.14

As a result of the confusing, inconsistent, and in some cases unenforceable changes made in the cost allowability rules setting caps on compensation costs in recent months, it is difficult to determine what rules apply to some contracts. We prepared the attached chart, which we hope will be useful, summarizing our understanding of the various sets of regulatory and statutory provisions that are likely to be applicable to currently active contracts as a tool for deciding how many alternative indirect cost submissions could be required.


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....