Articles and Blogs

On December 9, 2025, the Department of Health and Human Services’ (“HHS”) Office of the Inspector General (“OIG”) issued its annual solicitation for proposals and recommendations for developing new or modifying existing Anti-Kickback Statute (“AKS”) safe harbor provisions. In doing so, the OIG’s objective is to identify safe harbors that safeguard “beneficial and innocuous... READ MORE

NATIONAL 7 major vaccine policy changes in 2025 2026: Healthcare-specific private equity reporting requirements set to go into effect 40 million Americans use ChatGPT for healthcare: Report 13 health systems affected by Oracle Health data breach 6 Stark law cases in 1 year A 2026 Stark law update goes into effect Breaking the discharge... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) continues to scrutinize beneficiary transparency, medical necessity and data‑driven oversight of hospital billing and utilization. This scrutiny means continued compliance risk for hospitals. Two long‑standing compliance tools remain especially relevant for hospital leadership: the Medicare Outpatient Observation Notice (“MOON”) and the Program for Evaluating Payment Patterns... READ MORE

On December 29, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced the first round of awards under the Rural Health Transformation Program (“RHTP”), a $50 billion, five-year initiative intended to strengthen and modernize health care delivery in rural communities nationwide. All 50 states will receive funding beginning in Federal Fiscal Year (“FFY”)... READ MORE

NATIONAL 19 states, DC sue HHS over gender-affirming care restrictions 6 new care and payment models CMS introduced in 2025 14 Epic updates in 30 days 39 hospital M&As finalized in 2025 5 financial metrics health system leaders are targeting next year 11 states plan post-acute initiatives with CMS’ rural health fund 10 most... READ MORE

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

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

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