Articles and Blogs

Indiana Medicaid implemented significant updates for applied behavior analysis (“ABA”) therapy—one of the most widely used interventions for children with autism spectrum disorder—effective April 1, 2026. The reforms include phased cuts to reimbursement for ABA therapy, updates to member eligibility and revisions to provider qualifications. The Indiana Health Coverage Programs (“IHCP”) began covering ABA therapy…Read More

Our previous article, In Defense of IGTs from Governmental Health Care Providers, noted that the Secretary of the Department of Health and Human Services (“HHS”) is required to “consult with the States” before issuing any regulations changing the treatment of intergovernmental transfers (“IGTs”). We received requests for further information about this requirement following the publication…Read More

The Centurion Foundation has financially stabilized Roger Williams Medical Center and Our Lady of Fatima Hospital in Rhode Island and returned them to local nonprofit management through a bond-financed recapitalization exceeding $100M. The hospitals had been at risk of closure after their prior owner, Prospect Medical Holdings, filed for Chapter 11 bankruptcy in 2025. U.S….Read More

On March 20, 2026, Federal Trade Commission (“FTC”) Chairman Andrew Ferguson announced the formation of an internal Healthcare Task Force (the “Task Force”) and, in a memorandum issued the same day, directed the FTC’s Bureaus of Competition, Consumer Protection, and Economics, along with the Office of Policy Planning and the Office of Technology, to form…Read More

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 is…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 schemes…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 notification…Read More

Peer review investigations are a cornerstone of medical staff oversight. They protect patient safety, uphold professional standards and ensure compliance with federal law, state law and accreditation requirements. When concerns arise about a practitioner’s clinical competence or professional conduct, the process must be deliberate, fair and well-documented. Below are key considerations for conducting an effective…Read More