Who Knew? Limitations Defense Kept in Play Against U.S.
Client Alert | 1 min read | 07.23.12
In Sikorsky Aircraft Corp. v. U.S., the Court of Federal Claims found there to be triable issues of fact with regard to the contractor's statute of limitations defense as to when the government's claim accrued, i.e., when the government "knew or should have known" of alleged CAS 418 noncompliance. This case follows a series of similar recent cases at the CFC and the ASBCA and raises the issue of who in the government needs to have notice of a claim for it to accrue -- a contracting officer or "other responsible actors" such as DCAA auditors -- a question the court declined to resolve "[a]t this early juncture" in the proceedings.
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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.
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