- New federal law will require hospitals to obtain separate NPIs and submit provider‑based attestations for off‑campus hospital outpatient departments (“HOPDs”) as a condition of Medicare payment starting in 2028. The changes remove prior flexibility for HOPDs by stiffening ownership, compliance and structuring requirements for these facilities.
- Echoing other recent reports, a recent VMG Healthcare M&A Report found that overall health care M&A deal volume in 2025 remained below pre‑pandemic levels, while total deal value rebounded due to larger, strategic transactions driven by distress, consolidation and a shift toward outpatient care. From a real estate perspective, capital is moving away from traditional acute‑care hospitals toward ASCs, outpatient imaging, behavioral health, urgent care and home‑based/post‑acute platforms.
- The University of Texas System approved funding for a $300M expansion of its League City hospital campus. The project adds inpatient and clinical capacity, reinforcing continued capital investment in hospital‑based real estate despite broader outpatient care trends.
- Connecticut’s Public Health Committee advanced legislation that would prohibit hospitals from entering into sale‑leaseback transactions for their real estate. The proposal directly targets hospital real estate monetization strategies often used by private equity owners. A similar legislative effort failed in 2025.
- Stout published a 2026 ASC Valuation Survey indicating continued strong investor demand for ASCs, with stable to modestly increasing valuation multiples and controlling interests typically trading around 7.0x–8.9x EBITDA. From a real estate perspective, ASCs with favorable site characteristics, such as multi‑specialty layouts, expansion capacity and locations in CON states, command valuation premiums, while CON reform in several states is lowering barriers to de novo development.
- Congress extended CMS’s Acute Hospital Care at Home waiver for five years, allowing hospitals to continue providing inpatient‑level care in patients’ homes through 2030. From a real estate perspective, these extensions may reduce demand for traditional inpatient space while increasing the need for decentralized locations, such as small offices and storage spaces for medical equipment.
- The One Big Beautiful Bill Act includes a permanent 12% increase in the Low-Income Housing Tax Credit, which is a credit states receive from the federal government and can offer to developers to offset some of the construction costs of affordable housing projects. While tax-exempt hospitals may not benefit directly from the credit, they can benefit by joint venturing with a for-profit developer who can then pass along savings in the form of lower project costs and rents.
- Kennedy Krieger Institute plans to develop a new, $250M, 10-story Innovative Care Center in Baltimore to expand specialized pediatric and rehabilitation services. The project has received $6.75M of state funding so far, but the remainder of the facility is to be paid for primarily with donor funds.
- Maryland lawmakers proposed changes that would expand CON review to include health care mergers, acquisitions, formation of JVs and certain real estate transactions. If enacted, the legislation would add regulatory oversight to ASC development and health care real estate deals involving changes of control.
- A CommonSpirit Health hospital in Tacoma plans to convert an unused on‑campus suite into a 16‑bed infusion center. Several other health systems are working to expand infusion services, including Cone Health, John Muir Health and Northwell Health.
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