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
Legislation
CMS Proposes Several Changes Affecting Telehealth Services in the 2026 Medicare Physician Fee Schedule Proposed Rule
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…
HRSA Publishes 340B Rebate Pilot Program FAQs
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…
HHS Publishes 340B Guidance Proposing Rebate Pilot Program
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…
Connecticut Budget Bill Reinforces EMTALA and Emergency Medical Services Obligations for State Hospitals
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 Budget Bill Includes Notable Changes to CON Laws
On June 30, 2025 Connecticut Governor Ned Lamont signed a bill implementing the state budget through June 30, 2027, Public Act No. 25-168 (PA-168). PA-168, among other things, contains changes to the state’s Certificate of Need (CON) program.
Termination of Services – Effective from Passage
In Connecticut, hospitals generally must obtain CON approval…
Connecticut Enacts Wide-Ranging Health Care Law Modifying Various Existing Rules and Laws
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…
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
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…
Medicare Telehealth Flexibilities Extended through September 30, 2025
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…