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
Licensure
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…
Joint Commission Releases Guidance for AI in Health Care
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…
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…
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…
Connecticut Establishes Emergency Certificate of Need Process for Hospitals in Bankruptcy
*This post was authored with Paul Palma, law intern at Robinson+Cole. Paul is not admitted to practice law.
On March 3, 2025, Connecticut Governor Ned Lamont signed a law establishing a new process for hospitals in bankruptcy to apply for an “emergency certificate of need” (CON) to approve a transfer of ownership. The law, titled …
CMS Updates Guidance to Allow Texting of Patient Orders
On February 8, 2024, the Centers for Medicare and Medicaid Services (CMS) issued a quality standard memorandum (QSO Memo) updating and revising a memorandum it issued on January 5, 2018, to now permit the texting of patient orders among members of the patient’s health care team. CMS’s 2018 memorandum clarified CMS’s then-current position that texting…
New York Implements Health Equity Impact Assessment as New Requirement for Certificate of Need Process
On June 22, 2023, New York State Public Health Law § 2802-b, added a Health Equity Impact Assessment (HEIA) to the Certificate of Need (CON) process for certain health care facilities. The new requirement comes as part of larger legislative changes to the Public Health Laws passed in 2021. The new HEIA requirement applies to any CON applications submitted on or after June 22, 2023, except there is a partial carve out for Diagnostic and Treatment Centers whose patient population is 50 percent or more Medicaid eligible or uninsured. The Department of Health also issued regulations on June 29, 2023 (10 NYCRR 400.26). The purpose of the HEIA is to understand the health equity impact on a specific project, the impact it may have on medically underserved groups and to ensure community input and assessment are considered. The Department of Health has expressed that their vision is “to have health equity considerations meaningfully impact the planning and execution of health care facility projects.” (NYSDOH, Health Equity Impact Assessment, Webinar Series: Program Documents, September 14, 2023.)
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