On June 11, 2025, the Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 25-03 (the Advisory Opinion), in which OIG approved of a proposed arrangement under which a management support organization and a physician-owned professional corporation (the Requestors) would enter into an arrangement involving the leasing of clinical employees
Academic Medical Centers
Connecticut Governor Signs Bill Codifying the Right of Minors to Consent to Reproductive Health Care Services
On June 9, 2025, Connecticut Governor Ned Lamont signed into law Public Act No. 25-28, “An Act Concerning Access to Reproductive Health Care” (the Act). The Act codifies under Connecticut state law the ability of minors to access reproductive health care services without the need to obtain parental consent, including services related to pregnancy…
CMS Issues Guidance and Requests Information to Promote Hospital Price Transparency Compliance and Enforcement Efforts
By Conor Duffy on
On May 22, 2025, the Centers for Medicare & Medicaid Services (CMS) took a series of actions to promote enhanced price transparency compliance by hospitals and identify challenges thereto, in order to inform future price transparency enforcement activities and policies. These actions were taken in furtherance of the President’s February 2025 Executive Order No. 14221…
U.S. Supreme Court Denies DSH Hospitals’ Attempts to Seek Higher Medicare Payments
On April 29, 2025, the U.S. Supreme Court issued an opinion upholding the formula the U.S. Department of Health and Human Services (HHS) utilized to calculate Medicare hospitals’ disproportionate share hospital (DSH) payment adjustments, denying a challenge brought by hospitals seeking higher DSH reimbursement. In Advocate Christ Medical Center v. Kennedy, No. 23-715 (S.
Medicare Telehealth Flexibilities Extended through September 30, 2025
By Conor Duffy, Danielle Tangorre, Michael Lisitano & Guest Contributor on
Posted in Academic Medical Centers, Accountable Care Organizations, COVID-19, Government Enforcement, Health Information Technology, Health Policy, Hospitals and Health Systems, Legislation, Licensure, Physicians and Allied Health Professionals, Privacy and Security, Reimbursement, Telehealth, Telemedicine
This post is co-authored by Seth Orkand, co-chair of Robinson+Cole’s Government Enforcement and White-Collar Defense Team and Paul Palma, law intern at Robinson+Cole. Paul is not admitted to practice law.
On March 14, 2025, as part of a spending bill to avert a federal government shutdown, Congress extended COVID-era telehealth “waivers” applicable to Medicare…
Connecticut Establishes Emergency Certificate of Need Process for Hospitals in Bankruptcy
By Conor Duffy, Michael Lisitano & Guest Contributor on
*This post was authored with Paul Palma, law intern at Robinson+Cole. Paul is not admitted to practice law.
On March 3, 2025, Connecticut Governor Ned Lamont signed a law establishing a new process for hospitals in bankruptcy to apply for an “emergency certificate of need” (CON) to approve a transfer of ownership. The law, titled …
Trump Administration Issues Executive Order Prioritizing Hospital Price Transparency Enforcement
On February 25, 2025, President Donald Trump issued an Executive Order titled “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information” (the 2025 Order). The 2025 Order directs federal agencies to take various actions to prioritize enforcement of healthcare price transparency requirements for hospitals and health plans “to support…
OIG Audit Scrutinizes Hospital Compliance with Price Transparency Rule
By Michael Lisitano, Conor Duffy & Guest Contributor on
*This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
In November 2024, the Department of Health and Human Services Office of Inspector General (OIG) published the results of its audit assessing hospital compliance with the federal Hospital Price Transparency Rule (HPT Rule). OIG determined that 37…
CMS Finalizes Standard for Identifying Overpayments and Grace Period for Investigations of Related Overpayments
By Conor Duffy & Leslie Levinson on
Posted in Academic Medical Centers, Ambulatory Surgical Centers (ASC), Department of Justice, False Claims Act, Fraud and Abuse, Government Enforcement, Health Policy, Home Health/ Home Care, Hospice, Hospitals and Health Systems, Laboratories, Long Term Care and Nursing Homes, Pharmaceuticals and Biologics, Pharmacy Law, Physicians and Allied Health Professionals, Private Equity, Reimbursement, Stark Law, Telehealth, Telemedicine
As part of its 2025 Physician Fee Schedule Final Rule (PFS Rule), the Centers for Medicare & Medicaid Services (CMS) finalized two crucial updates to federal Medicare overpayments regulations (sometimes referred to as the “60-Day Rule”) that (1) align the standard for when an overpayment is identified with the applicable standard under the…
Massachusetts Supreme Court Rules Online Tracking Technologies Do Not Violate State Wiretap Law
In a highly anticipated decision on an issue facing courts across the country, the Massachusetts Supreme Judicial Court held in late October that Massachusetts hospitals’ use of online tracking technologies that collect and transmit browsing activities of website visitors does not violate the Massachusetts Wiretap Law.
The Court determined that online interactions between visitors and…