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
Government Enforcement
Hospitals Face New Attestation and NPI Requirements for Off-Campus Outpatient Locations by January 1, 2028
The Consolidated Appropriations Act of 2026, HR 7148 (the Act), just signed into law on February 3, 2026, ended a brief government shutdown and includes multiple provisions with a critical impact on health care organizations. We have previously covered the Act’s renewal and extension through 2027 of COVID-era Medicare telehealth flexibilities and its revisions to…
Two Weeks Notice for Covered Entities: February 16 Deadline Approaches to Update HIPAA Notice of Privacy Practices
By Conor Duffy on
Posted in Academic Medical Centers, Government Enforcement, Health Information Exchanges and Electronic Medical Records (EMRs), Health Information Technology, Health Policy, HIPAA, Hospitals and Health Systems, Legislation, Licensure, Physicians and Allied Health Professionals, Tax Exemption/Charitable Organizations
February 16, 2026, is the deadline for each HIPAA covered entity to update its Notice of Privacy Practices (NPP) to incorporate new regulatory requirements enacted in 2024. Specifically, HIPAA-covered entities (including health care providers and health plans) are required to review and revise their NPPs as necessary to ensure compliance with a 2024 federal rulemaking…
DEA Extends Tele-Prescribing Flexibilities Yet Again – Now Through December 31, 2026 – to Avoid Telemedicine Cliff
On December 31, 2025, the federal Drug Enforcement Administration (DEA) extended current regulatory flexibilities related to tele-prescribing of controlled substances for another year. The DEA issued a fourth temporary extension (2026 Extension) of its pandemic-era telehealth flexibilities, which are now scheduled to end on December 31, 2026. The DEA explained that another extension…
Appeals Dropped of Decision Vacating HIPAA Reproductive Health Privacy Rule, Confirming Apparent End of the Rule and Attestation Requirement
By Conor Duffy & Ivy Miller on
On September 10, 2025, the U.S. Court of Appeals for the Fifth Circuit dismissed an appeal of the federal court ruling vacating key provisions of the HIPAA reproductive health care regulations, which appears to signal the end of the Purl case (previously discussed here) and to confirm the end of provisions of the HIPAA…
Connecticut Budget Bill Reinforces EMTALA and Emergency Medical Services Obligations for State Hospitals
By Conor Duffy, Josh Yoo & Guest Contributor on
This post was co-authored with Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
On June 30, 2025, Connecticut Governor Ned Lamont signed into law Public Act No. 25-168 (PA 25-168) (the Act), Connecticut’s Budget Bill for the period between July 1, 2025, and June 30, 2027. The Act includes two…
Connecticut Enacts Wide-Ranging Health Care Law Modifying Various Existing Rules and Laws
By Nathaniel Arden, Victoria Larson & Ivy Miller on
On June 25, 2025, Connecticut Governor Ned Lamont signed into law Public Act No. 25-97, “An Act Concerning Various Revisions to the Public Health Statutes” (the Act). The Act includes a wide range of provisions affecting patient confidentiality, hospital and provider licensure, scope of practice, civil penalties, and Connecticut’s statewide health information exchange. Significant…
OIG Green Lights MSO Model Arrangement for Telehealth Platforms in New Advisory Opinion
By Conor Duffy & Guest Contributor on
This post was co-authored with Ivy Miller, legal intern at Robinson+Cole. Ivy is admitted to practice law in Massachusetts.
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…
False Claims Act Enforcement of Pharmacy Pricing & Prescribing Practices: The Walgreens Cases
By Yelena Greenberg, Danielle Tangorre & Guest Contributor on
This post was co-authored with Ivy Miller, legal intern at Robinson+Cole. Ivy is admitted to practice law in Massachusetts.
The Department of Justice has launched a number of enforcement actions targeting pharmacies for alleged violations of the False Claims Act (FCA). Recently, Walgreens has been the subject of two noteworthy government settlements related to alleged…
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…