Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”) has announced the nationwide implementation of a new Risk-Based Survey (“RBS”) process for qualifying nursing homes beginning September 8, 2026. CMS Memorandum QSO-26-14-NH explains that the RBS is intended to allow State Survey Agencies (“SAs”) to use fewer survey resources at higher-performing facilities and redirect resources... READ MORE

Over the past few years, we’ve seen an increase in hospitals and health care systems using credit tenant lease (“CTL”) financing for new outpatient projects. Below is an overview of CTL financing. Overview – CTL financing has been around for many years. In some circles, it’s referred to as lease financing or synthetic lease... READ MORE

NATIONAL 340B purchases reach record $100B: 5 things to know AHA urges court to reject AbbVie bid to change 340B program rules Amazon Pharmacy brings real-time drug pricing to clinicians CMS’ fraud crackdown may not be catching much fraud: Study Democratic bid to end WISeR prior authorizations program fails Digital health funding hits $7.4B... READ MORE

The U.S. Food and Drug Administration (“FDA”) is seeking public input as it prepares its 2026 report on the risks and benefits to health associated with non-device software functions, including their impact on patient safety and related best practices. Stakeholders have only about one month to submit comments, which are due by August 13,... READ MORE

On April 30, 2026, at the Health Care Compliance Association’s 2026 Compliance Institute, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) introduced its updated Corporate Integrity Agreement (“CIA”) template, using the Kinex Medical Company CIA as its model. The updated template retains the core elements of an effective compliance... READ MORE

The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) recently issued Advisory Opinion 26-15 addressing a subscription-based referral management software platform used during hospital discharge planning. OIG concluded that, under the facts presented, the arrangement could generate prohibited remuneration under the Federal Anti-Kickback Statute (“AKS”) because providers paying subscription fees... READ MORE

Williamson Health’s (Franklin, TN) Board of Trustees has voted to sell the county-owned health system to Ascension. The total value of the deal is over $950M, including a $700M purchase price and over $250M in commitments for facility improvements, electronic health records and other strategic projects. The deal remains subject to approval by the Williamson County Commissioners. Bridgepoint... READ MORE

National 17 health systems affected by Oracle Health data breach CMS proposes to slash 340B payments to hospitals CMS scraps ‘fast-track’ process for certain Medicaid waivers: 6 things to know CMS unveils 2027 outpatient payment plan: Questions and answers CMS takes aim at 340B, site-neural payments in OPPS proposal CVS, Omnicare reach $440M settlement... READ MORE

The results of the 2026 National Health Care Fraud Takedown (the “Takedown”) were announced on June 23, 2026; the Department of Justice (“DOJ”) charged 455 individuals in connection with alleged health care fraud schemes involving over $6.5 billion in false claims. Ninety of the charged individuals were physicians or other medical professionals. The Takedown,... READ MORE

Earlier this year, Congress enacted Section 6225 of the Consolidated Appropriations Act, 2026 (“CAA”), establishing a new Medicare condition of payment for off-campus hospital outpatient departments beginning January 1, 2028. As discussed in our prior alerts (here and here), the statute generally prohibits Medicare payment for services furnished by an off-campus hospital outpatient department... READ MORE