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
Hall, Render, Killian, Heath & Lyman, P.C. Blog
The Hall, Render, Killian, Heath & Lyman, P.C. Blog focuses on legal issues related to healthcare real estate, hospital development, and healthcare regulatory compliance. It covers topics such as hospital campus land acquisitions, mixed-use healthcare projects, healthcare real estate investment trends, and construction contract risk management. The blog also addresses regulatory updates including CMS price transparency rules and enforcement, as well as strategic healthcare operational models like population health services organizations. It provides insights into healthcare finance, tax considerations for nonprofit hospitals, and the evolving landscape of healthcare delivery and infrastructure development.
Latest from Hall, Render, Killian, Heath & Lyman, P.C. Blog - Page 4
Ninth Circuit Permits 340B-Based FCA Claims to Proceed Despite Lack of Private Right of Action
By Hall Render
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
By Hall Render
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…
Weekly Hospital Real Estate Briefing: Five Takeaways from Our Hospital Campus Development Trends Webinar
By Hall Render
On March 12, we hosted a webinar titled Hospital Campus Development: Current Deals, Trends and Insights Learned Along the Way. To watch a video replay of the webinar and to get copies of our slides, click here.Here are our…
Medicare Advantage Industry Segment-Specific Compliance Program Guidance Issued
By Hall Render
The U.S. Department of Health & Human Services Office of Inspector General (“OIG”) has long been the north star for health care entities seeking guidance on creating and implementing an effective compliance program. As the author of the General Compliance…
GLP-1 Gold Rush Meets Legal Reality: Novo Nordisk Challenges Compounded Alternatives
By Hall Render
The continued expansion of GLP-1 weight-loss therapies has introduced both commercial opportunity and evolving legal and regulatory considerations across the health care landscape. Novo Nordisk’s (“Novo”) recent federal lawsuit against Hims & Hers (“Hims”) illustrates how brand manufacturers may increasingly…
Separate NPI and Attestation Requirements for Off-Campus Departments: Steps Hospitals Should Take Now
By Hall Render
Congress recently enacted the Consolidated Appropriations Act of 2026, which includes new Medicare conditions of payment for off-campus hospital outpatient departments. Beginning January 1, 2028, Medicare payments will not be made for items and services furnished by an off-campus department…
OIG Offers Contemporary Guidance on Various Discount Constructs in Recent Advisory Opinion
By Hall Render
On December 15, 2025, the Office of Inspector General (“OIG”) issued Advisory Opinion No. 25‑11 (“Advisory Opinion”) and concluded it would not impose administrative sanctions under the federal Anti‑Kickback Statute (“AKS”) on a biopharmaceutical manufacturer for a series of discounts…
CMS Solicits Comments on Potential Approaches to Strengthen the American-Made Supply Chain
By Hall Render
On January 26, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”) seeking public input on potential policies to strengthen the domestic supply chain for personal protective equipment (“PPE”) and essential medicines…
FY 2027 H-1B Cap: What Employers Need to Know About the New System
By Hall Render
The fiscal year (“FY”) 2027 H-1B cap season will be the first to operate under a weighted selection system that replaces the prior fully random lottery. Employers should understand how this new process affects both the regular (bachelor’s) cap and…