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
Hospitals and Health Systems
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…
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…
Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities
This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
On February 3, 2026, President Trump signed HR 7148, the Consolidated Appropriations Act, 2026 (“the Act”) ending the 4-day partial government shutdown. The Act, part of a broader fiscal year (FY) 2026 spending package, includes a…
Two Weeks Notice for Covered Entities: February 16 Deadline Approaches to Update HIPAA Notice of Privacy Practices
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…
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…
Massachusetts Governor Healey Announces New Department of Insurance Regulations Intended to Streamline Prior Authorization Practices
On January 14, 2026, Massachusetts Governor Maura Healey announced that the Division of Insurance (DOI) will be promulgating updates to its regulations with the intent of streamlining prior authorization practices for health insurance claims. According to the Governor, the DOI regulations “will reduce unnecessary delays and cut administrative burdens to make it easier, cheaper and faster for people to get the medications and care…
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…