Articles and Blogs

On March 24, 2026, the U.S. Department of Health and Human Services (“HHS”), through the Centers for Medicare & Medicaid Services (“CMS”), published a long‑anticipated final rule adopting national Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) standards for health care claims attachments transactions and electronic signatures (the “Final Rule”). The Final Rule... READ MORE

In a significant decision with implications for 340B enforcement and False Claims Act (“FCA”) whistleblower litigation, the United States Court of Appeals for the Ninth Circuit (the “Court”) held on March 17, 2026, that a health system (the “System”) may proceed with its qui tam action alleging that pharmaceutical manufacturers engaged in fraudulent price-inflation... READ MORE

On March 19, 2026, the U.S. Court of Appeals for the Fifth Circuit denied the Federal Trade Commission’s (“FTC”) motion for a stay pending appeal of the U.S. District Court for the Eastern District of Texas’s (the “District Court”) decision vacating the FTC’s 2024 Final Rule (the “2024 Rule”) revising the Hart‑Scott‑Rodino (“HSR”) premerger... READ MORE

NATIONAL 5 new things to know about the No Surprises Act: GAO report Amazon expands Health AI beyond the One Medical platform Amazon launches health AI agent on its website, expands free virtual care to 200M Prime members Big Pharma Gets Win in RFK Jr. Vaccine Pause, Unsure If It Lasts Bipartisan bill introduced... READ MORE

The Tenth Circuit recently issued two companion decisions confirming the Occupational Safety and Health Administration’s (“OSHA”) authority to cite employers for workplace violence hazards under the General Duty Clause of the Occupational Safety and Health Act, 29 U.S.C. § 654(a)(1) (“General Duty Clause”). In both cases, the Tenth Circuit upheld OSHA’s enforcement actions and the... READ MORE

Once again, 2025 was a busy year for health care data privacy. Ensuring up-to-date and compliant data privacy and security programs and being able to assess, understand and adapt to the risk of evolving technologies will remain critically important in 2026. We continue to await updated regulations under both the Health Insurance Portability and... READ MORE

On March 11, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued a Quality, Safety & Oversight (“QSO”) memorandum and related updates to the State Operations Manual (“SOM”) interpretive guidance clarifying and reinforcing existing responsibilities of organ procurement organizations (“OPOs”) and donor hospitals throughout the organ donation process. While the memorandum largely reiterates... READ MORE

NATIONAL 84% of primary care providers say they have key role in mental healthcare: Survey Aetna to pay $118M to settle Medicare Advantage upcoding claims A.I. Chatbots Want Your Health Records. Tread Carefully. Epic sued over claims MyChart fragments patient medical records Federal Medicaid fraud probe spreads to 10 states FDA vaccine chief to... READ MORE

The U.S. Department of Health & Human Services Office of Inspector General (“OIG”) has long been the north star for health care entities seeking guidance on creating and implementing an effective compliance program. As the author of the General Compliance Program Guidance (“GCPG”), OIG has used its years of investigative and oversight experience with... READ MORE

The Centers for Medicare and Medicaid Services (“CMS“) issued a wide-ranging Request for Information (“RFI”) on February 26, which could reshape current program integrity efforts to prevent and detect fraud, waste and abuse in government health care programs. CMS, under its new Comprehensive Regulations to Uncover Suspicious Healthcare (“CRUSH”) initiative, is seeking stakeholder input... READ MORE