Articles and Blogs

Effective January 6, 2022, the Federal Communications Commission (“FCC”) implemented phase two of its multi-line telephone systems (“MLTS”) E911 regulations. On a prospective basis, communication systems that interface with the public switched telephone network (i.e., technologies that permit a user to place an out-bound telephone call) must generally comply with the enhanced 911 calling requirements…Read More

On March 1, 2022, President Biden outlined his plan to increase the quality of patient care, resident safety, regulations, fines and ownership transparency in skilled nursing care during his State of the Union address. The day before, on February 28, 2022, President Biden released a fact sheet titled “FACT SHEET: Protecting Seniors and People with…Read More

Our Health Care Real Estate Briefing is your comprehensive summary of weekly health care real estate highlights currently happening across the nation. News surrounding skilled nursing facilities (“SNFs”) continued to dominate headlines after President Biden took aim at the quality of care being provided at privately-owned SNFs. Additionally, a number of operators and trade associations fired…Read More

The Centers for Medicare & Medicaid Services (“CMS”) recently announced the ACO Realizing Equity, Access, and Community Health (“REACH”) Model.  The ACO REACH Model is designed to replace the Global and Professional Direct Contracting (“GPDC”) Model, which we previously discussed here. The application period for the ACO REACH Model opens Monday, March 7, 2022, and closes…Read More

Our Health Care Real Estate Briefing is your comprehensive summary of weekly health care real estate highlights currently happening across the nation. Last week, there were quite a few stories about hospitals and health care facilities that are worth mentioning. Most of the headlines were about skilled nursing facilities (“SNFs”), the lack of staffing and how…Read More

On February 23, 2022, the U.S. District Court for the Eastern District of Texas (the “Court”) vacated key portions of a regulation implementing the independent dispute resolution (“IDR”) process under the No Surprises Act (the “Act”). An interim final rule published in the Federal Register on October 7, 2021 (the “Rule”) implementing certain parts of…Read More

On February 4, 2022, the Department of Health & Human Services Office of Inspector General (“OIG”) issued Advisory Opinion 22-02 protecting a children’s hospital’s donor-funded charity program (“Proposed Arrangement”). Under the Proposed Arrangement, the requestor (“Children’s Hospital”) would use funds from two individual donors to establish a restricted endowment fund that would subsidize patient bills…Read More

As required by the Physician Payments Sunshine Act (“Sunshine Act”), by March 31, 2022, manufacturers of many drugs, medical devices, biologicals and other medical supplies, as well as applicable group purchasing organizations (“GPOs”), will report to CMS payments made and other investment interests given in 2021 to physicians, teaching hospitals and — for the first…Read More