Articles and Blogs

When equity interests in a passthrough entity are sold, such transaction documents are often described as “partnership interest purchase agreements,” “membership interest purchase agreements” or “equity purchase agreements.” However, under U.S. federal income tax rules, a transaction that is legally structured as an equity purchase can sometimes be treated (in whole or in part)... READ MORE

On April 14, 2026, the Centers for Medicare & Medicaid Services (“CMS”) published the fiscal year (FY) 2027 Inpatient Prospective Payment System (IPPS) proposed rule (the “Proposed Rule”) in the Federal Register, which included several proposals that would affect organ acquisition reimbursement policies for Independent Organ Procurement Organizations (“IOPOs”), as well as Organ Procurement... READ MORE

On March 26, 2026, the Eighth Circuit, in Ghosh v. Abbott Lab’ys, Inc., 170 F.4th 1141 (8th Cir. 2026), affirmed the dismissal of whistleblower claims brought by a remote employee whose connections to Minnesota, where the employer was located, consisted of a 12-day visit to the state to participate in mandatory training. Case Background... READ MORE

The first nationwide test of a mandatory episode-based payment model has been unveiled. In the Fiscal Year (“FY”) 2027 Inpatient Prospective Payment System (“IPPS”) Proposed Rule, the Centers for Medicare & Medicaid Services (“CMS”) proposes resurrecting and expanding the original Comprehensive Care for Joint Replacement (“CJR”) Model to establish a mandatory, nationwide episode-based payment model for most hospitals paid under... READ MORE

NATIONAL 150+ healthcare organizations accepted into CMS’ ACCESS Model AbbVie challenges ‘outdated’ 340B drug discount program guidance in new lawsuit AHA names its preferred cybersecurity provider CMS accepts more than 150 providers, digital health firms for ACCESS model CMS Launches First Wave of Health Tech Ecosystem Health Information Sharing and Access Tools CMS pitches... READ MORE

The FFY 2027 IPPS Proposed Rule (“Proposed Rule”) was released on April 10, 2026, and CMS published the associated tables on its Proposed Rule homepage. The Proposed Rule was published in the Federal Register on April 14. The release of the Proposed Rule and the accompanying tables triggers the start of several deadlines for... READ MORE

NATIONAL 5 fights disrupting the physician workforce 4 Joint Commission moves 3 million in rural counties lose MA coverage: Report A dismantled federal patient care research agency: 9 updates AbbVie sues HHS over 340B patient definition CDC clears path for 2nd vaccine advisory panel overhaul CMS finalizes Medicare Advantage star ratings overhaul, sending billions... READ MORE

The U.S. Department of Labor issued a Proposed Rule that would significantly change prevailing wage calculations for foreign workers under the permanent labor certification, H-1B, H-1B1 and E-3 visa programs. At the center of the proposal is an increase in the prevailing wage levels based more heavily on statistically derived wage percentiles from the... READ MORE

No contract, no problem—at least for now. An Illinois district court (the “Court”) opened the door for hospitals to recover underpaid claims from insurers—holding that a quantum meruit claim may proceed even absent any contract. Lucile Salter Packard Children’s Hosp. v. Health Care Servs. Corp., 2026 WL 278804, No. 25-cv-04533, at *1 (N.D. Ill.... READ MORE

NATIONAL 4 senators push CMS to tackle Medicare Advantage upcoding: Bloomberg 7 health systems with boosted outlooks 131 hospitals sue HHS over DSH cuts: 5 notes ACA plans denied 19% of in-network claims in 2024: report AHA urges CMS to limit hospital burden in fraud crackdown, calls for MA scrutiny Bipartisan bill would cap... READ MORE