Articles and Blogs

The Centers for Medicare & Medicaid Services (“CMS”) continues to scrutinize beneficiary transparency, medical necessity and data‑driven oversight of hospital billing and utilization. This scrutiny means continued compliance risk for hospitals. Two long‑standing compliance tools remain especially relevant for hospital leadership: the Medicare Outpatient Observation Notice (“MOON”) and the Program for Evaluating Payment Patterns Electronic…Read More

On December 29, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced the first round of awards under the Rural Health Transformation Program (“RHTP”), a $50 billion, five-year initiative intended to strengthen and modernize health care delivery in rural communities nationwide. All 50 states will receive funding beginning in Federal Fiscal Year (“FFY”) 2026,…Read More

We hope everyone enjoyed some time off over the holidays. As we reflect on 2025 and head into the new year, we spent some time mapping out our hospital real estate predictions for 2026. We believe it will be a mixed bag for hospitals and health systems around the country. Most hospital systems will face…Read More

On Tuesday, December 30, 2025, the Drug Enforcement Administration (“DEA”) and the Department of Health and Human Services (“HHS,” and together with the DEA, the “Agencies”) issued a fourth temporary rule (the “Fourth Temporary Rule”) extending the COVID-19-era telemedicine flexibilities for prescribing Schedule II–V controlled substances through December 31, 2026. The extension allows DEA-registered practitioners to…Read More

Under the federal Stark Law (the “Stark Law”), hospitals, physician groups, labs and other provider entities may provide non-monetary (i.e., non-cash or cash-equivalent) compensation to physicians up to an aggregate amount of $535 for calendar year 2026. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its medical…Read More

Revista published a pair of interesting blog posts: (1) the amount of general hospital space under construction in Q3 of 2025 has continued a multi-year climb that started in 2022; and (2) noting that the least expensive MOB rents (bottom 10th percentile) have grown at just 1.3%/yr since 2018, while moderately priced properties (50th percentile…Read More

Until this year, the Food and Drug Administration’s (“FDA” or “agency”) Office of Prescription Drug Promotion (“OPDP”) enforcement activity had settled into a relatively predictable pattern. In both 2023 and 2024, OPDP issued five enforcement letters each year, reinforcing a perception that the agency was exercising restraint and directing its limited resources toward more complex…Read More

As we head into the holidays, we want to thank you for being a valued reader of our Weekly Hospital Real Estate Briefing. We hope you are able to enjoy time with friends and family in the days ahead. To provide you with a few timely topics to consider over the holidays, we’ve compiled a…Read More