Articles and Blogs

On September 29, 2026, in LifeLink Foundation, Inc. v. Kennedy, the U.S. District Court for the Middle District of Florida (the “Court”) upheld the Centers for Medicare & Medicaid Services (“CMS”) 2020 rule governing Organ Procurement Organization (“OPO”) performance measures and tier classifications (the “Final Rule”). The decision rejects one significant legal challenge to the…Read More

The Illinois General Assembly recently enacted HB 3392, which amends several provisions of the Illinois Assisted Living and Shared Housing Act (“Act”). The legislation imposes new assessment requirements, modifies qualifications for assisted living directors, updates medication administration provisions, revises dementia care requirements and strengthens enforcement authority for repeated compliance deficiencies. The law took effect immediately…Read More

On October 1, 2026, Colin M. McDonald, Assistant Attorney General for the National Fraud Enforcement Division (“NFED” or the “Fraud Division”), issued a memorandum (the “Memo”) announcing key priorities of the Fraud Division’s Corporate Enforcement Section. The Memo follows significant changes to internal U.S. Department of Justice (“DOJ”) workflows for criminal fraud enforcement and the…Read More

In revisions released earlier this year to its General Questions Regarding Certain Fraud and Abuse Authorities, the Office of Inspector General (“OIG”) emphasized that compliance with the physician self-referral law (“Stark Law”) does not automatically resolve risk under the federal Anti-Kickback Statute (“AKS”). Furthermore, OIG clarified that fair market value (“FMV”) compensation, by itself, does…Read More

The U.S. Department of Justice (“DOJ”) recently revised its Justice Manual to strengthen its approach to False Claims Act (“FCA”) enforcement. The revisions address two issues particularly relevant to FCA defendants: the use of sub-regulatory guidance and DOJ’s consideration of dismissing declined qui tam actions. DOJ Reinforces Limits on Sub-Regulatory Guidance The revised Justice Manual…Read More

On September 18, 2026, President Trump issued two related measures affecting the H-1B program—a Proclamation extending the $100,000 H-1B fee to certain H-1B workers and an Executive Order directing federal agencies to strengthen H-1B oversight, including by considering employers’ recent or planned layoffs of similarly situated U.S. workers. The $100,000 fee, which applies to certain…Read More

Survey Snapshot We received over 60 responses to our recent hospital real estate executive survey. Over the next few weeks, we will highlight some of the noteworthy and surprising results on current trends, strategic priorities and challenges facing hospital real estate professionals. When asked, “What are your organization’s top real estate priorities in 2027?,” one…Read More

The U.S. Department of Justice (“DOJ”) recently issued a memorandum announcing the priorities of its newly established National Fraud Enforcement Division (the “Division”), identifying health care fraud as a key enforcement focus. The Division was created to combat fraud and will concentrate its efforts on public trust and financial integrity, health care, internal revenue, global…Read More