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"//signed//" Doesn't Cut It

Client Alert | less than 1 min read | 04.30.08

A claim certification was invalid, and the ASBCA had no jurisdiction to decide the case, when the contractor's president submitted it by email and simply typed "//signed//" above his name. The Board in Teknocraft Inc. (Apr. 3, 2008) acknowledged that both the contractor and the government had used the typed designation "//signed//" in their emails during performance, but held that "//signed//" was not a "discrete, verifiable symbol of an individual" and constituted an "incurable defect" in the certification.

Insights

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....