On May 1, 2026, the Department of Health and Human Services Office of Inspector General (“OIG”) posted Advisory Opinion 26-09 (“AO 26-09”), which opines on a pediatric dental and orthodontic service provider’s (“Requestor’s”) proposal to offer free orthodontic treatment for
Hall, Render, Killian, Heath & Lyman, P.C.
Hall, Render, Killian, Heath & Lyman, P.C. is a law firm specializing in health care law with a focus on hospital and health system clients. The firm publishes detailed analyses and updates on topics such as hospital real estate development, health care regulatory compliance, price transparency rules, and population health management. Their content often covers legal and operational issues affecting nonprofit and for-profit hospitals, including construction and development projects, regulatory changes by CMS, and strategic trends in health care delivery and financing. The firm provides insights into health care real estate transactions, hospital expansion, and evolving care models like population health services organizations.
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Weekly Hospital Real Estate Briefing: OIG Issues Advisory Opinion on Lease Arrangements | Health Care Construction Costs Level Out
Indiana Medicaid Seeks Moratorium for ABA Provider Enrollment
Indiana Medicaid’s effort to rein in Applied Behavior Analysis (“ABA”) therapy costs has led to a proposed moratorium on provider enrollment. On May 7, 2026, the Indiana Health Coverage Programs (“IHCP”) announced it is seeking approval from the Centers for…
CMS Moratorium on New Medicare Home Health and Hospice Enrollment
On May 13, 2026, as part of its ongoing effort to address home health and hospice fraud, the Trump administration announced a 6-month moratorium on new Home Health and Hospice enrollment, effective immediately. The federal register notice for home health…
FDA Issues RFI on AI-Enabled Optimization of Early-Phase Clinical Trials Pilot Program
On April 29, 2026, the U.S. Food and Drug Administration (“FDA” or the “Agency”) issued a Request for Information (“RFI”) seeking stakeholder input on a proposed pilot program evaluating the use of artificial intelligence (“AI”) to optimize early-phase clinical trials.The…
FDA Moves Toward Real-Time Clinical Trial Modernization
On April 28, 2026, the U.S. Food and Drug Administration (“FDA”) announced additional steps in its ongoing initiative to advance real-time clinical trial approaches, including proof-of-concept studies and a request for information supporting a planned pilot program focused on real-time…
Bill Ouska Joins Hall Render as Shareholder
Hall Render is pleased to announce that Bill Ouska has joined the Firm as a Shareholder in its Dallas office.Bill is a health care transactions attorney who advises health care organizations, private equity sponsors, dental support organizations and individual business…
CMS Releases FFY 2027 IPPS Proposed Rule; Wage Index Deadlines
The FFY 2027 IPPS Proposed Rule (“Proposed Rule”) was released on April 10, 2026, and CMS published the associated tables on its Proposed Rule homepage. The Proposed Rule is expected to be published in the Federal Register on April…
Ninth Circuit Permits 340B-Based FCA Claims to Proceed Despite Lack of Private Right of Action
In a significant decision with implications for 340B enforcement and False Claims Act (“FCA”) whistleblower litigation, the United States Court of Appeals for the Ninth Circuit (the “Court”) held on March 17, 2026, that a health system (the “System”) may…
Fifth Circuit Denies FTC Stay: HSR Filings Revert to Old Form Effective Immediately
On March 19, 2026, the U.S. Court of Appeals for the Fifth Circuit denied the Federal Trade Commission’s (“FTC”) motion for a stay pending appeal of the U.S. District Court for the Eastern District of Texas’s (the “District Court”) decision…