Articles and Blogs

On Tuesday, December 30, 2025, the Drug Enforcement Administration (“DEA”) and the Department of Health and Human Services (“HHS,” and together with the DEA, the “Agencies”) issued a fourth temporary rule (the “Fourth Temporary Rule”) extending the COVID-19-era telemedicine flexibilities for prescribing Schedule II–V controlled substances through December 31, 2026. The extension allows DEA-registered practitioners... READ MORE

Under the federal Stark Law (the “Stark Law”), hospitals, physician groups, labs and other provider entities may provide non-monetary (i.e., non-cash or cash-equivalent) compensation to physicians up to an aggregate amount of $535 for calendar year 2026. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its... READ MORE

Revista published a pair of interesting blog posts: (1) the amount of general hospital space under construction in Q3 of 2025 has continued a multi-year climb that started in 2022; and (2) noting that the least expensive MOB rents (bottom 10th percentile) have grown at just 1.3%/yr since 2018, while moderately priced properties (50th... READ MORE

Until this year, the Food and Drug Administration’s (“FDA” or “agency”) Office of Prescription Drug Promotion (“OPDP”) enforcement activity had settled into a relatively predictable pattern. In both 2023 and 2024, OPDP issued five enforcement letters each year, reinforcing a perception that the agency was exercising restraint and directing its limited resources toward more... READ MORE

As we head into the holidays, we want to thank you for being a valued reader of our Weekly Hospital Real Estate Briefing. We hope you are able to enjoy time with friends and family in the days ahead. To provide you with a few timely topics to consider over the holidays, we’ve compiled... READ MORE

On December 18, 2025, the Centers for Medicare & Medicaid Services (“CMS”) issued two proposed rules aimed at limiting provision of gender-affirming care to minors (each a “Proposed Rule” and, collectively, the “Proposed Rules”). The first rule would add a new Condition of Participation (“CoP”), prohibiting a hospital from performing “sex-rejecting procedures” on minors, in... READ MORE

**There will be no distribution of this newsletter next week. Happy Holidays!** NATIONAL 47 states introduced healthcare AI bills in 2025 CMS floats 24 measure updates: 7 things to know CMS proposes funding blocks on gender-affirming care for minors CMS launches ‘MAHA Elevate’ to test lifestyle medicine in Medicare FAH taps new CEO FDA... READ MORE

On December 11, 2025, the Centers for Medicare & Medicaid Services (“CMS”) extended the due date indefinitely to complete and submit the new Form CMS-855A Skilled Nursing Facility  (“SNF”) Disclosures Attachment for every SNF. In its Medicare Learning Network, 2025-12-11-MLNC, CMS formally announced that enrolled SNFs should continue collecting data on ownership, managerial, and related party... READ MORE

Fitch Ratings’ 2026 outlook for the nonprofit hospital sector was “neutral,” and forecasts median operating margins between 1-2%, while noting largely healthy volume trends and strong balance sheets. It expects a roughly equal number of ratings downgrades and upgrades among its portfolio, and noted that the industry is still investing in patient tower and... READ MORE

NATIONAL 57 health systems ask HHS to rescind cybersecurity rule ACA approval hits new high as subsidies set to expire: 7 things to know American Hospital Association President and CEO to retire AHA supports federal AI safety guidance AHA warns of ‘​10 out of 10’ cyber vulnerability CMS’ final ASC rule overall ‘positive’: Inside... READ MORE