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Weakened Dollar Causes Further Rise In TAA Thresholds

Client Alert | 1 min read | 01.04.10

Effective January 1, 2010, the U.S. Trade Representative has revised upward the contract dollar thresholds at which the Buy American Act restriction is waived for the supply of goods and services or construction material from "designated countries" (i.e., those countries that have signed the WTO Agreement on Government Procurement ("GPA") or other free trade agreement with the U.S.) (74 Fed. Reg. 68907, Dec. 29, 2009). Because the GPA thresholds are expressed in "Special Drawing Rights," the USTR adjusts the thresholds biennially and the U.S. dollar's continued weakness has resulted in the third straight increase, to $203,000 for goods and services and $7,804,000 for construction contracts.

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Client Alert | 2 min read | 02.03.26

CMS Doubles Down on RADV Audit Changes

On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025....