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
Health Policy
Song Remains the Same – Medicare Telehealth Services At Risk of Expiring Again on January 30, 2026
Healthcare providers are currently facing yet another termination of Medicare telehealth flexibilities at the end of the day on January 30, 2026, unless Congress acts on proposals to further extend the COVID-era flexibilities for telehealth. If no legislative action is taken before January 30, 2026, the providers and Medicare patients who have depended on expanded…
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…
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…
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…
Update on Processing of Telehealth Claims Impacted During the Government Shutdown
The recent government shutdown caused multiple Medicare statutory payment provisions to lapse on October 1, 2025, due to the absence of Congressional action. With the passage of the Continuing Appropriations, Agriculture, Legislative Branch, Military Construction and Veterans Affairs, and Extensions Act, 2026 (Pub. L. 119-37), (discussed here), Congress has retroactively restored many of these…
Telehealth Survives Again: What the Most Recent Flexibility Extension Means for Providers
This post is co-authored with Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
On November 12, 2025, President Trump signed H.R. 5371 the “Continuing Appropriations, Agriculture, Legislative Branch, Military Construction, and Veterans Affairs and Extensions Act, 2026” (the Act). The Act ended the federal government shutdown by providing necessary funding…
Telehealth Services on the Brink Again – Is a 7-Week Stopgap the Only Fix?
This post is co-authored with Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
Healthcare providers are again confronted with the potential termination of telehealth services unless Congress acts to extend the Medicare flexibilities implemented during the COVID-19 pandemic. If no legislative action is taken before September 30, 2025, those providers…
Appeals Dropped of Decision Vacating HIPAA Reproductive Health Privacy Rule, Confirming Apparent End of the Rule and Attestation Requirement
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…