Articles and Blogs

On March 12, we hosted a webinar titled Hospital Campus Development: Current Deals, Trends and Insights Learned Along the Way. To watch a video replay of the webinar and to get copies of our slides, click here. Here are our top five takeaways from the webinar: Paging Dr. Strategy: Your Real Estate Is Calling –…Read More

On March 11, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued a Quality, Safety & Oversight (“QSO”) memorandum and related updates to the State Operations Manual (“SOM”) interpretive guidance clarifying and reinforcing existing responsibilities of organ procurement organizations (“OPOs”) and donor hospitals throughout the organ donation process. While the memorandum largely reiterates existing…Read More

The U.S. Department of Health & Human Services Office of Inspector General (“OIG”) has long been the north star for health care entities seeking guidance on creating and implementing an effective compliance program. As the author of the General Compliance Program Guidance (“GCPG”), OIG has used its years of investigative and oversight experience with health…Read More

The Centers for Medicare and Medicaid Services (“CMS“) issued a wide-ranging Request for Information (“RFI”) on February 26, which could reshape current program integrity efforts to prevent and detect fraud, waste and abuse in government health care programs. CMS, under its new Comprehensive Regulations to Uncover Suspicious Healthcare (“CRUSH”) initiative, is seeking stakeholder input on…Read More

The Indiana Court of Appeals recently affirmed a regular commitment to a state hospital of a gravely disabled patient based on evidence that the patient’s symptoms impaired his judgment and his refusal to take medication and behavior demonstrated his inability to function independently. In re Commitment of G.S. v. Richmond State Hosp., No. 25A-MH-2033, 2026…Read More

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