On May 14, 2026, Connecticut Governor Ned Lamont signed Public Act No. 26-13, “An Act Concerning Various Revisions to the Public Health Statutes” (the “Act”) into law. The Act contains numerous revisions to State public health and health care laws, and several provisions deserve close attention from health care organizations, including hospitals and health
Health Care
Connecticut Establishes New Process for Hospitals Seeking to Pause or Terminate Service Lines
On May 26, 2026, Connecticut Governor Ned Lamont signed a bill overhauling the state’s Certificate of Need (CON) program which, among other things, eliminates the current CON approval requirement for a hospital to terminate services. A new process for hospitals to provide notice of service suspensions and terminations is part of the State’s budget bill,…
Everything Old is New Again: Connecticut Revamps Certificate of Need (CON) Program under Department of Public Health
On May 2, 2026, the Connecticut Legislature approved the overhaul of the state’s Certificate of Need (CON) program as part of its appropriations bill for the fiscal year ending June 30, 2027, Public Act No. 26-68 (“the Act”).
The Act significantly revises all aspects of the CON program and process, including most notably by eliminating…
OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk
On April 23, 2026, the HHS Office of Inspector General (OIG) quietly—but pointedly—added two new FAQs to its “General Questions Regarding Certain Fraud and Abuse Authorities.” Although the principles articulated are not new, the timing and clarity of these FAQs reflect OIG’s continued effort to correct common—and risky—misunderstandings in the health care industry regarding the…
Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority
On February 5, 2026, the Massachusetts Health Policy Commission (HPC) published proposed amendments to its Material Change regulations at 958 CMR 7.00 (the Proposed Amendments). Among other things, the Proposed Amendments broaden the HPC’s market review authority by subjecting more transactions to the HPC’s Material Change Notice (MCN) process and provide the HPC greater latitude…
Hospitals Face New Attestation and NPI Requirements for Off-Campus Outpatient Locations by January 1, 2028
By Conor Duffy & Josh Yoo
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…
HRSA Requests Comments on Second Iteration of 340B Rebates
On February 17, 2026, the Health Resources and Services Administration (HRSA) issued a Request for Information (RFI) regarding the use of rebates within the 340B Program. After an unsuccessful first attempt at deploying a rebate model late last year (as we previously wrote about here and here), HRSA is now seeking “input from interested…
New Year Brings Old Obligations with a Recent Twist: PAMA Reporting is Back
After uncertainty over the last few months, the last few weeks saw potential changes to the Protecting Access to Medicare Act of 2014 (PAMA) under section 6226 of the Consolidated Appropriations Act of 2026. On January 20, 2026, the House Appropriations Committee released the Consolidated Appropriations Act 2026, which included several healthcare extenders, among them…
Two Weeks Notice for Covered Entities: February 16 Deadline Approaches to Update HIPAA Notice of Privacy Practices
By Conor Duffy
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…
Continuing Appropriations Act, 2026: Another Lifeline for Medicare Telehealth Flexibilities
This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
On February 3, 2026, President Trump signed HR 7148, the “Consolidated Appropriations Act, 2026” (the Act) ending the 4-day partial government shutdown. The Act, part of a broader fiscal year (FY) 2026 spending package, includes a…