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Crowell Talks Tax: The Inflation Reduction Act's Domestic Content Bonus Credits (VIDEO)

Client Alert | 12 min read | 03.13.24

Government Contracts and International Trade partner Addie Cliffe and Government Contracts counsel Liam O’Reilly discuss the Inflation Reduction Act’s Domestic Content Bonus Credits.

Key Takeaways:

  • Does my project qualify
  • Distinguishing between iron and steel vs manufactured products
  • Tracking “components”; and
  • Importance of monitoring the IRS continued implementation of this program as changes occur

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Insights

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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....