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Andrew Bettwy

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other… more

Anti-Terrorism Financing, Beneficial Owner, Corporate Transparency Act, FinCEN, Healthcare

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Guy Brenner

OSHA Releases Emergency Temporary Standards to Protect Healthcare Workers from COVID-19 Infection

On June 10, 2021, the U.S. Department of Labor Occupational Safety and Health Administration (“OSHA”) announced “an emergency temporary standard to protect healthcare workers from contracting coronavirus.” The standard focuses… more

Coronavirus/COVID-19, Health and Safety, Health Care Providers, Healthcare Facilities, Healthcare Workers

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Timothy Burroughs

As Scrutiny Escalates, DOJ Announces the Formation of the Health Care Monopolies and Collusion Task Force

The U.S. Department of Justice (“DOJ”) recently announced the creation of the Health Care Monopolies and Collusion Task Force (the “HCMC Task Force”) aimed at resolving antitrust issues in the health care industry… more

Antitrust Division, Collusion, Data Protection, Department of Justice (DOJ), Federal Trade Commission (FTC)

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Gary Creem

New York’s New Notice Requirement for Practice Management Deals Demonstrates a Trend That Should be Carefully Watched

Following New York State Governor Kathy Hochul’s proposal in February of this year (see our previous alert), the New York legislature passed and Governor Hochul signed a law on May 3, 2023, which significantly increases the… more

Confidentiality Policies, Disclosure Requirements, Health Care Providers, New York, Proposed Regulation

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Charles Dale

Diagnosing Distress: Top 5 Challenges for Private Credit Lenders in Health Care Restructurings

Despite the strength of the U.S. economy headed into the New Year, a variety of conditions may be conspiring against businesses in certain segments of the health care industry. These include reduced patient census at skilled… more

Borrowers, Chapter 11, Commercial Bankruptcy, Default, Dischargeable Debts

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Jacquelyn Daniel

DOJ’s Civil Rights Fraud Initiative: Key Considerations for Health Care Providers

The Department of Justice’s (“DOJ”) May 19, 2025 “Civil Rights Fraud Initiative” memorandum, issued by Deputy Attorney General Todd Blanche (the “Initiative”), marks a consequential policy shift for False Claims Act (“FCA”)… more

Colleges, Department of Health and Human Services (HHS), Department of Justice (DOJ), Diversity and Inclusion Standards (D&I), Enforcement Actions

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Peter Eggers

Home Is Where the Health Care Is: New Study Shows Increase in Number of Homebound Older Adults While CMS Expands Home Health Reimbursement Model

JAMA Internal Medicine recently published an article finding that the number of homebound adults aged 70 or older more than doubled during the last decade. In 2011, approximately 5% of adults aged 70 or older were homebound… more

Centers for Medicare & Medicaid Services (CMS), Health Care Providers, Healthcare Reform, Home Health Care, Medicare

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Jeffrey Horwitz

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other… more

Anti-Terrorism Financing, Beneficial Owner, Corporate Transparency Act, FinCEN, Healthcare

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Vincent Indelicato

Diagnosing Distress: Top 5 Challenges for Private Credit Lenders in Health Care Restructurings

Despite the strength of the U.S. economy headed into the New Year, a variety of conditions may be conspiring against businesses in certain segments of the health care industry. These include reduced patient census at skilled… more

Borrowers, Chapter 11, Commercial Bankruptcy, Default, Dischargeable Debts

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John Ingrassia

As Scrutiny Escalates, DOJ Announces the Formation of the Health Care Monopolies and Collusion Task Force

The U.S. Department of Justice (“DOJ”) recently announced the creation of the Health Care Monopolies and Collusion Task Force (the “HCMC Task Force”) aimed at resolving antitrust issues in the health care industry… more

Antitrust Division, Collusion, Data Protection, Department of Justice (DOJ), Federal Trade Commission (FTC)

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Vinay Kohli

No Surprises Here! Payers Push Back on IDR Submissions, Opening New Front in NSA Implementation Landscape

On May 27, 2025, Blue Cross Blue Shield Healthcare Plan of Georgia (“BCBSGA”) sued several emergency physician groups and their billing agent, Halo MD, alleging abuse of the No Surprises Act’s (“NSA”) independent dispute… more

Arbitration, Commercial Insurance Policies, Dispute Resolution, Federal Arbitration Act, Healthcare

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Edward Kornreich

Recent FCA and AKS Litigation Highlights Use of Different Standards in Different Circuits

In an important decision limiting the reach of the Federal Anti-Kickback Statute (42 U.S.C. 1320a-7b(b)) (“AKS”) and its application to violations of the False Claims Act (31 U.S.C. 3729, et seq.) (“FCA”), the U.S. Court of… more

Anti-Kickback Statute, Appeals, But For Causation, Causation, Department of Health and Human Services (HHS)

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Jason Madden

DOJ Targets Gender‑Affirming Care under FDCA and FCA: Scrutinizes Off‑Label Drug Use and False Diagnosis Codes

Last month, the United States Department of Justice (“DOJ”) issued its “Civil Division Enforcement Priorities” memorandum, memorializing a shift from its predecessor administration’s policy on gender‑affirming healthcare (“DOJ… more

Department of Justice (DOJ), Enforcement Actions, False Claims Act (FCA), Federal Food Drug and Cosmetic Act (FFDCA), Federal Funding

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David Manko

DOJ Targets Gender‑Affirming Care under FDCA and FCA: Scrutinizes Off‑Label Drug Use and False Diagnosis Codes

Last month, the United States Department of Justice (“DOJ”) issued its “Civil Division Enforcement Priorities” memorandum, memorializing a shift from its predecessor administration’s policy on gender‑affirming healthcare (“DOJ… more

Department of Justice (DOJ), Enforcement Actions, False Claims Act (FCA), Federal Food Drug and Cosmetic Act (FFDCA), Federal Funding

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Michael Menconi

CMS to Immediately Begin Auditing Medicare Advantage Plans in Significant Expansion of Enforcement Efforts

On May 21, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced a significant expansion of its auditing efforts with respect to Medicare Advantage (“MA”) plans… more

Audits, Centers for Medicare & Medicaid Services (CMS), Enforcement Actions, Healthcare, Healthcare Fraud

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Ellen Moskowitz

DOJ’s Civil Rights Fraud Initiative: Key Considerations for Health Care Providers

The Department of Justice’s (“DOJ”) May 19, 2025 “Civil Rights Fraud Initiative” memorandum, issued by Deputy Attorney General Todd Blanche (the “Initiative”), marks a consequential policy shift for False Claims Act (“FCA”)… more

Colleges, Department of Health and Human Services (HHS), Department of Justice (DOJ), Diversity and Inclusion Standards (D&I), Enforcement Actions

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Krusheeta Patel

Physician Fee Schedule Final Rule for Calendar Year 2022 – CMS Cuts Rates and Extends Telehealth

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) issued its Calendar Year (CY) 2022 Physician Fee Schedule (“PFS”) Final Rule. In this post, we sample some key highlights from the Final Rule… more

Centers for Medicare & Medicaid Services (CMS), FQHC, Health Care Providers, Healthcare, Healthcare Reform

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Precious Penny

As Scrutiny Escalates, DOJ Announces the Formation of the Health Care Monopolies and Collusion Task Force

The U.S. Department of Justice (“DOJ”) recently announced the creation of the Health Care Monopolies and Collusion Task Force (the “HCMC Task Force”) aimed at resolving antitrust issues in the health care industry… more

Antitrust Division, Collusion, Data Protection, Department of Justice (DOJ), Federal Trade Commission (FTC)

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Whitney Phelps

This New Year, California Imposes Guardrails on the Use of AI by Payors for Utilization Management Determinations

SB 1120 (the “Bill”), which takes effect on January 1, 2025, amends existing California law to adopt guardrails around the use of artificial intelligence tools for the purpose of utilization management. As discussed in a prior… more

Algorithms, Anti-Discrimination Policies, Artificial Intelligence, Audits, California

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Jonian Rafti

DOJ Targets Gender‑Affirming Care under FDCA and FCA: Scrutinizes Off‑Label Drug Use and False Diagnosis Codes

Last month, the United States Department of Justice (“DOJ”) issued its “Civil Division Enforcement Priorities” memorandum, memorializing a shift from its predecessor administration’s policy on gender‑affirming healthcare (“DOJ… more

Department of Justice (DOJ), Enforcement Actions, False Claims Act (FCA), Federal Food Drug and Cosmetic Act (FFDCA), Federal Funding

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D. Austin Rettew

No Surprises Here! Payers Push Back on IDR Submissions, Opening New Front in NSA Implementation Landscape

On May 27, 2025, Blue Cross Blue Shield Healthcare Plan of Georgia (“BCBSGA”) sued several emergency physician groups and their billing agent, Halo MD, alleging abuse of the No Surprises Act’s (“NSA”) independent dispute… more

Arbitration, Commercial Insurance Policies, Dispute Resolution, Federal Arbitration Act, Healthcare

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Alexandra Rueckle Reynolds

OSHA Releases Emergency Temporary Standards to Protect Healthcare Workers from COVID-19 Infection

On June 10, 2021, the U.S. Department of Labor Occupational Safety and Health Administration (“OSHA”) announced “an emergency temporary standard to protect healthcare workers from contracting coronavirus.” The standard focuses… more

Coronavirus/COVID-19, Health and Safety, Health Care Providers, Healthcare Facilities, Healthcare Workers

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Ashley Seibler

Arrangements Involving Intraoperative Neuromonitoring Continue to be Scrutinized under the Federal Anti-Kickback Statute

This week, the U.S. Attorney’s Office for the District of Colorado (“USAO”) announced that it entered into a series of interrelated settlement agreements with companies that provide intraoperative neuromonitoring (“IONM”)… more

Advisory Opinions, Anti-Kickback Statute, Compliance, Department of Health and Human Services (HHS), Federal Health Care Programs (FHCP)

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Leslie Shanklin

Shortly After its Online Tracking Technologies Bulletin is Declared Unlawful, HHS-OCR Stands Down, Withdraws Appeal

On August 29, 2024, the Office for Civil Rights of the United States Department of Health and Human Services (“HHS-OCR”) withdrew its appeal of an order by the United States District Court for the Northern District of Texas’… more

Administrative Procedure Act, Class Action, Covered Entities, Department of Health and Human Services (HHS), Health Insurance Portability and Accountability Act (HIPAA)

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Elanit Snow

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other… more

Anti-Terrorism Financing, Beneficial Owner, Corporate Transparency Act, FinCEN, Healthcare

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Yuval Tal

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other… more

Anti-Terrorism Financing, Beneficial Owner, Corporate Transparency Act, FinCEN, Healthcare

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Patrick Walling

New York’s New Notice Requirement for Practice Management Deals Demonstrates a Trend That Should be Carefully Watched

Following New York State Governor Kathy Hochul’s proposal in February of this year (see our previous alert), the New York legislature passed and Governor Hochul signed a law on May 3, 2023, which significantly increases the… more

Confidentiality Policies, Disclosure Requirements, Health Care Providers, New York, Proposed Regulation

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Matthew Westbrook

No Surprises Here! Payers Push Back on IDR Submissions, Opening New Front in NSA Implementation Landscape

On May 27, 2025, Blue Cross Blue Shield Healthcare Plan of Georgia (“BCBSGA”) sued several emergency physician groups and their billing agent, Halo MD, alleging abuse of the No Surprises Act’s (“NSA”) independent dispute… more

Arbitration, Commercial Insurance Policies, Dispute Resolution, Federal Arbitration Act, Healthcare

See all updates »

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