The Small Business Runway Extension Act Is One Step Closer to Take Off
Client Alert | 1 min read | 07.08.19
On June 24, 2019, the U.S. Small Business Administration published a rule proposing to amend the time period for calculating average annual receipts for SBA’s receipts-based size standards from three to five years. This rule would implement the congressional intent behind the Small Business Runway Extension Act of 2018, which the SBA previously instructed did not permit small businesses to immediately begin certifying against a five-year time period. In the proposed rule, the SBA again warns that the three-year calculation period continues to apply to any offer submitted prior to the effective date of a final rule. Comments on the proposed rule are due by August 23, 2019.
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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.
Client Alert | 2 min read | 02.03.26
Sedona Model Jury Instructions for DTSA: A Step Forward—But Questions Remain
Client Alert | 7 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
