Hospitals and Health Systems

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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…

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…

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…

This post is co-authored with Lauren Ludwig, legal intern at Robinson+Cole. Lauren is not admitted to practice law.

The Joint Commission (TJC) and Coalition for Health AI (CHAI) recently published the Guidance on the Responsible Use of Artificial Intelligence in Healthcare (Guidance), which outlines strategies for health care organizations to optimize their integration of health…

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…

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…

This post is co-authored with Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.

On July 14, 2025, the Centers for Medicare and Medicaid Services (CMS) issued the calendar year (CY) 2026 physician fee schedule (PFS) proposed rule, which in pertinent part proposes several changes affecting the delivery and reimbursement…

On August 6, 2025, the New York Department of Health finalized and made effective significant changes to the Certificate of Need (CON) review process for health facility construction projects. The changes amend § 710.1 of Title 10 of the New York Codes, Rules, and Regulations (NYCRR), streamlining regulatory review and raising cost thresholds to reflect…

As previously discussed in our prior blog post, on August 1, 2025, the Department of Health and Human Services (HHS) issued a Notice announcing a much-anticipated 340B Rebate Model Pilot Program (Pilot Program). Subsequently, the Health Resources and Services Administration (HRSA), which administers the 340B program, issued a set of FAQs providing additional guidance…

This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.

On July 31, 2025, the Department of Health and Human Services (HHS) announced a much-anticipated 340B Rebate Model Pilot Program (Pilot Program) via guidance (Guidance) that will be formally published on August 1, 2025. The Pilot Program…