Last month, the U.S. Department of Health and Human Services Office of Inspector (“OIG”) released a report that studied prior authorization denials and payment denials by Medicare Advantage Organizations (“MAOs”) (the “Report”). While the Report found that the “vast majority”
On April 29, 2022, the Centers for Medicare and Medicaid Services (“CMS”), issued the final rule on Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs (the “Final Rule”). CMS promotes the
The Federal Acquisition Regulatory Council (the “FAR Council”) currently is considering amendments to the Federal Acquisition Regulation (“FAR”) that would elevate the consideration of climate-related risks in Federal Government contracting. The draft proposed rules aim to implement key sections of
Federal cannabis reform is once again on the move in Congress. On Friday, April 1, 2022, the U.S. House of Representatives passed the latest iteration of the Marijuana Opportunity Reinvestment and Expungement (MORE) Act. This is Congress’s oldest comprehensive measure,
Procurement Collusion Strike Force
The Procurement Collusion Strike Force, formed by the Department of Justice in 2019, is ramping up enforcement pressures against government contractors. The Strike Force brings together the DOJ Antitrust Division criminal offices, state Attorneys General,
The inattention some companies pay to their ethics and compliance program never ceases to surprise us. You’d think the frequency of DOJ press releases and prosecutions holding companies accountable for employee wrongdoing would be enough to scare any business into
Updated as of May 24, 2022
The United States is engaging in a new form of warfare. Russia invaded Ukraine just over two months ago and, rather than join the fight directly by sending troops to defend Ukraine, the United
On April 18, 2022, the Biden Administration (through the Office of Management and Budget (“OMB”)) issued OMB Memorandum M-22-11 (the “Guidance”)[1] relating to the “Buy America” sourcing requirements under the “Build America, Buy America” portion of the Infrastructure Investment
The Small Business Administration’s (“SBA”) Office of Hearing and Appeals (“OHA”) rejected a small business government contractor’s 8(a) participation determination appeal as untimely, notwithstanding the contractor’s claim the termination letter at issue was sent to a junk email folder.
On March 18, 2022, the Department of Defense (“DOD”) issued its long-awaited Final Rule implementing Section 818 of the National Defense Authorization Act for Fiscal Year 2018 (“NDAA FY 2018”), and formally codifying defense contractors’ rights to post-award enhanced debriefings.