Connecticut Governor Ned Lamont recently signed into law Public Act No. 26-68 (the Act), which makes targeted but significant changes to the Department of Public Health’s (DPH) enforcement authority for health care licensure and certification violations by increasing potential fines and creating criminal liability for certain unlicensed operation of health care institutions and unlicensed provision of
Connecticut Updates its Medical Orders for Life-Sustaining Treatment Program
Connecticut Governor Ned Lamont recently signed Public Act No. 26-68 (the Act), which includes changes to the state’s medical orders for life-sustaining treatment (MOLST) program. Shortly after the Act was signed into law, the Connecticut Department of Public Health (DPH) issued policies and procedures regarding the MOLST program, which will operate as regulations in the
Massachusetts HPC Expands Reporting Requirements and Oversight Authority in New Material Change Regulations
On April 16, 2026, the Massachusetts Health Policy Commission (HPC) approved amendments to its Material Change Notice (MCN) regulations at 958 CMR 7.00 (the Amended Regulations), which went into effect on May 8, 2026. As background, following the 2025 passage of health care legislation that expanded the HPC’s health care market oversight responsibilities, the HPC
Connecticut Disbands Office of Health Strategy and Reassigns Health Care Oversight and Policymaking Authority Across State Agencies
Connecticut Governor Ned Lamont recently signed Public Act No. 26-68 (“the Act”), which includes the elimination of the Office of Health Strategy (OHS) and reassignment of its statutory authority over the health care delivery system in Connecticut. The Act’s repeal of OHS’s enabling statute and the transfer of its authority to other state agencies are scheduled
How PBM Reform Suddenly Got Rolling
Below is an excerpt of an article published in the Massachusetts Bar Association’s Section Review.
Recent months have seen a significant shift in how pharmacy benefit managers (PBMs) are regulated at both the state and federal levels. PBMs are hired by health plans to manage administrative and other duties, while also serving as intermediaries
Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority
On February 5, 2026, the Massachusetts Health Policy Commission (HPC) published proposed amendments to its Material Change regulations at 958 CMR 7.00 (the Proposed Amendments). Among other things, the Proposed Amendments broaden the HPC’s market review authority by subjecting more transactions to the HPC’s Material Change Notice (MCN) process and provide the HPC greater latitude
HRSA Requests Comments on Second Iteration of 340B Rebates
On February 17, 2026, the Health Resources and Services Administration (HRSA) issued a Request for Information (RFI) regarding the use of rebates within the 340B Program. After an unsuccessful first attempt at deploying a rebate model late last year (as we previously wrote about here and here), HRSA is now seeking “input from interested
Government Withdraws Appeal in 340B Rebate Pilot Program Litigation, Signaling Shift
The recent litigation concerning the government’s 340B Rebate Model Pilot Program (the Rebate Program), as further described below, took an unexpected turn as the federal government recently signaled that it intended to revise its approach to the Rebate Program. This change in strategy was previewed by the government in a letter filed with the Court
Court Issues Nationwide Preliminary Injunction of the 340B Rebate Model Pilot Program
On December 29, 2025—just three days before the 340B Rebate Model Pilot Program (the Rebate Program) was set to begin—the U.S. District Court for the District of Maine issued an order granting a preliminary injunction to block the government’s implementation of the Rebate Program on January 1, 2026, after determining that the Health Resources and
CMS Adds New Requirements to Hospital Price Transparency Reporting
On November 21, 2025, the Centers for Medicare & Medicaid Services (CMS) published the CY 2026 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Final Rule (the Rule), which includes several significant changes to hospital price transparency regulations. The changes follow from Executive Order 14221, entitled “Making America Healthy Again by Empowering Patients