Articles and Blogs

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…Read More

UPDATE: March 10, 2026 – The dispute between Novo Nordisk (“Novo”) and Hims & Hers (“Hims”) appears to have been resolved very quickly. On March 9, the companies announced an agreement allowing Hims to offer FDA-approved Wegovy® and Ozempic®, including the recently released tablets, through its telehealth platform at the same self-pay prices as other…Read More

Congress recently enacted the Consolidated Appropriations Act of 2026, which includes new Medicare conditions of payment for off-campus hospital outpatient departments. Beginning January 1, 2028, Medicare payments will not be made for items and services furnished by an off-campus department unless the hospital satisfies new requirements related to location-specific National Provider Identifiers (“NPIs”) and provider-based…Read More

The Indiana Court of Appeals (the “Court”) confirmed that evidence about the patient’s indirect threats of physical and sexual violence can satisfy the Petitioner’s burden to clearly and convincingly prove that the patient is dangerous. In re Commitment of W.C. v. Richmond State Hosp., 272 N.E.3d 983 (Ind. Ct. App. 2025) (unpublished table opinion). Background…Read More

Good Samaritan Medical Center (FL) announced massive plans to redevelop its West Palm Beach campus into a mixed-use health care district. Plans include a new 225-bed hospital, a medical office tower, workforce housing, luxury condos, a hotel and other mixed-use amenities along the water. The project is estimated to cost between $2B to $3B. Cleveland…Read More

HIPAA covered entities and Part 2 Programs should be aware of two important compliance deadlines that may require prompt action. Annual HIPAA Small Breach Reporting Under the Breach Notification Rule, HIPAA covered entities are required to submit reports of certain breaches of unsecured protected health information (“PHI”) affecting fewer than 500 individuals to the HHS…Read More

Significant updates to the ALTA/NSPS Land Title Survey Standards will impact health care real estate transactions beginning February 23, 2026. The American Land Title Association (“ALTA”) and the National Society of Professional Surveyors (“NSPS”) have adopted updated Minimum Standard Detail Requirements for ALTA/NSPS Land Title Surveys (the “2026 Standards”), which take effect February 23, 2026,…Read More

In a recent interview, Alison Flynn Gaffney, CEO of two Banner Health hospitals, discussed how she applies a real estate perspective to hospital leadership. Prior to becoming CEO, she spent two years as president of the health care division at JLL, which imparted a unique perspective on leveraging hospital real estate portfolios for the benefit…Read More