The U.S. Department of Health and Human Services Office of Inspector General (“OIG”) issued Advisory Opinion No. 25-09 on August 12, 2025. The favorable opinion that found that a medical device manufacturer that was partly physician-owned qualified for the small
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CMS Announces Health Tech Ecosystem Initiative
The Centers for Medicare & Medicaid Services (“CMS”) has announced a Health Tech Ecosystem initiative, developed in response to a May 2025 request for information (“RFI”) to solicit suggestions from stakeholders on ways to modernize the nation’s digital health ecosystem.…
Refusing voyage orders: Sanctions risk assessments must be based on evidence, not speculation
Tonzip Maritime Ltd v. 2Rivers Pte Ltd (formerly Coral Energy Pte Ltd) [2025] EWHC 2036 (Comm)
A. Key facts
On 5 November 2021, Tonzip Maritime Ltd (Owners), owner of the vessel CATALAN SEA (the Vessel), entered into a voyage charterparty…
The contingent duty to indemnify
CMS makes changes to Medicare Part D bid parameters for 2026
The Centers for Medicare & Medicaid Services (“CMS”) announced preliminary Medicare Part D bid parameters for year 2026 to help plan sponsors finalize plan offerings and prepare for Medicare open enrollment in 2026.
Notably, the announcement includes various updates to…
Sixth Circuit Likely Next to Consider FCA’s Constitutionality Under Article II
On July 28, 2025, the U.S. District Court for the Southern District of Ohio certified for interlocutory appeal to the U.S. Court of Appeals for the Sixth Circuit the question of whether the False Claims Act’s qui tam provisions violate…
CFIUS annual report for 2024: Key takeaways
On August 6, 2025, the Committee on Foreign Investment in the United States (CFIUS) released its annual report to Congress for calendar year 2024. This annual publication includes the 325 covered transactions—consisting of 209 written notices and 116 declarations—that…
New California Medical Debt Disclosure Law Now in Effect—What Providers Need to Know Now
The Cyber Security and Resilience Bill
The Cyber Security and Resilience Bill (the “Bill”) will be introduced to Parliament in 2025 and will lead to a significant overhaul of the UK’s cybersecurity framework.
At present, the UK’s existing cybersecurity framework is governed by the Network and…
CMS Launches WISeR Model to Target Waste by Leveraging (Broken) Prior Authorization System
The Centers for Medicare & Medicaid Services (CMS) recently announced the launch of the Wasteful and Inappropriate Service Reduction (WISeR) Model – a six-year pilot program designed to reduce Medicare spending on select “wasteful (low-value) services shown to have little…
