Articles and Blogs

On December 15, 2025, the Office of Inspector General (“OIG”) issued Advisory Opinion No. 25‑11 (“Advisory Opinion”) and concluded it would not impose administrative sanctions under the federal Anti‑Kickback Statute (“AKS”) on a biopharmaceutical manufacturer for a series of discounts and rebates offered on multiple vaccines. Although portions of the arrangement failed to meet the…Read More

On January 26, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”) seeking public input on potential policies to strengthen the domestic supply chain for personal protective equipment (“PPE”) and essential medicines used by Medicare‑participating hospitals. The initiative reflects lessons learned during the COVID‑19 public health emergency…Read More

The fiscal year (“FY”) 2027 H-1B cap season will be the first to operate under a weighted selection system that replaces the prior fully random lottery. Employers should understand how this new process affects both the regular (bachelor’s) cap and the advanced degree (master’s) cap, as it changes selection mechanics but not the overall annual…Read More

On February 12, 2026, the U.S. District Court for the Eastern District of Texas (the “Court”) struck down the Federal Trade Commission’s (“FTC”) rule expanding the scope of the Hart-Scott-Rodino (“HSR”) Act Premerger Notification Form. See Chamber of Com. of the U.S. v. Fed. Trade Comm’n, No. 6:25-CV-9-JDK, 2026 WL 402498 (E.D. Tex. Feb. 12,…Read More

On January 30, 2026, the U.S. Department of Labor (“DOL”) proposed a regulation under the Employee Retirement Income Security Act (“ERISA”) that would require pharmacy benefit managers (“PBMs”) to make detailed disclosures to fiduciaries of employer-sponsored self-insured group health plans. The proposed regulation implements President Trump’s Executive Order 14273, Lowering Drug Prices by Once Again…Read More

On January 27, 2026, the U.S. Department of Health and Human Services (“HHS”) Office of the Inspector General (“OIG”) issued a Special Advisory Bulletin (the “Bulletin”) detailing how the federal Anti-Kickback Statute (“AKS”) applies to direct-to-consumer (“DTC”) prescription drug sales by manufacturers to cash-paying patients enrolled in federal health care programs. The Bulletin provides a…Read More

Health care jobs accounted for more than half of all new jobs created last month, according to the most recent Bureau of Labor Statistics jobs report. One article said the health care industry is “propping up the job market.” The fastest growing health care jobs are: 1) nurse practitioners; 2) medical services managers; and 3)…Read More

Health care continues to drive private equity (“PE”) activity, creating opportunities for investors and traditional health care providers. Transactions in the health care space are especially complicated, layering health care regulatory and reimbursement considerations on top of a complex securities, antitrust, privacy and security framework. Hall Render’s PE team of attorneys and advisors leverage the…Read More

Effective January 1, 2026, the Centers for Medicare & Medicaid Services (“CMS”) implemented significant changes to the accreditation and enrollment framework for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) suppliers through the CY 2026 Home Health Prospective Payment System Final Rule (“Final Rule”). CMS adopted these changes in response to what it describes as…Read More