The Centers for Medicare & Medicaid Services (CMS) has proposed changes that could reshape how healthcare providers use electronic prior authorization starting in 2027. The alert examines the agency’s proposed calendar year (CY) 2027 Physician Fee Schedule rule, which would
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DOJ Issues First Healthcare Declination Under Revised Corporate Enforcement Policy: Key Takeaways for Healthcare Companies and MSOs
The Department of Justice (DOJ) has issued its first healthcare-related corporate declination under its revised Corporate Enforcement and Voluntary Self-Disclosure Policy, declining to prosecute a management services organization (MSO) while simultaneously indicting the former CEO and founder of the underlying…
New Oregon HCMO Rules Bring Higher Fees, New Penalties, and Deal Timing Requirements
Oregon’s Health Care Market Oversight (HCMO) program regulations underwent significant amendments that took effect on July 1, 2026, expanding which entities may qualify as “out-of-state” for HCMO purposes, narrowing the internal reorganization exclusion, and substantially increasing review fees. Preliminary review…
Health Reimbursement Signals: CMS Proposes Significant Changes to RPM and RTM Requirements
The Centers for Medicare & Medicaid Services (CMS) has proposed significant changes to Medicare reimbursement for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services under the proposed calendar year (CY) 2027 Medicare Physician Fee Schedule. The changes would…
Ninth Circuit Addresses CFAA and Agentic AI Tools in Groundbreaking Decision
On August 4, 2026, the U.S. Court of Appeals for the Ninth Circuit issued a groundbreaking decision in Amazon.com Services, LLC v. Perplexity AI, addressing the legal status of so-called “agentic AI” tools, which help users expedite various online…
EU AI Act Enforcement Phase Begins
On August 2, 2026, the European Commission (EC), acting through its European AI Office (EU AI Office), became formally entitled to exercise its powers to investigate and enforce the EU AI Act obligations imposed on providers of general-purpose artificial intelligence…
Status of California Climate Laws: Deadline for SB 253 Reporting Delayed Until November; SB 261 Remains Stayed
Our recent Client Alert provides an update on the status of California’s climate disclosure laws including the California Air Resources Board’s (CARB’s) plan to defer the SB 253 deadline for reporting Scope 1 and Scope 2 greenhouse gas emissions from…
ISS Announces Launch of 2026 Annual Global Benchmark Policy Survey
On July 21, 2026, ISS STOXX Governance (ISS) announced the launch of its 2026 Annual Global Benchmark Policy Survey. The survey results will inform ISS’s policy development for 2027 and beyond. For the U.S. market, the survey solicits views…
SEC Proposes Regulation E-Delivery: What This Could Mean for Delivery of Your Proxy Materials
On July 16, 2026, the U.S. Securities and Exchange Commission (the SEC or the Commission) proposed Regulation E-Delivery (Reg E-Delivery), a new framework that would permit issuers and market intermediaries to deliver required disclosures and reports electronically as the default…
Illinois Enacts AI Safety and Transparency Law for Frontier AI Developers
On July 6, 2026, Illinois Governor JB Pritzker signed into law Senate Bill 315, the Artificial Intelligence Safety Measures Act (AISMA), which will require large AI developers to publicly disclose how they plan to mitigate potentially “catastrophic risks” posed…