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
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Hospitals Face New Attestation and NPI Requirements for Off-Campus Outpatient Locations by January 1, 2028
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
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…
Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals
This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
Introduction
On January 28, 2026, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released a new report analyzing Medicare Part B (Part B) spending on laboratory tests in 2024. The Protecting Access…
DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025
This post was co-authored by Paul Palma, legal intern at Robinson+Cole. Paul is not admitted to practice law.
The final quarter of 2025 saw continued enforcement actions against clinical labs and other related healthcare entities. The Office of Inspector General (OIG) and Department of Justice (DOJ) heavily focused on False Claims Act (FCA) violations, Anti-Kickback…
Eliminating Kickbacks in Recovery Act – 2025 Updates and Looking to 2026
The Eliminating Kickbacks in Recovery Act (EKRA), enacted in 2018 as part of the SUPPORT Act, established a criminal statute prohibiting payments for patient referrals related to recovery homes, clinical treatment facilities, and laboratories. EKRA mostly mirrors the Anti-Kickback Statute (AKS) but extends its reach to commercial health insurance as well as federal programs like…
Search Bars, Chatbots, and Tracking Pixels: Practical Steps Labs Can Take to Reduce CIPA Risk in 2026
Plaintiffs’ firms are adapting the California Invasion of Privacy Act (CIPA), a 1960s-era wiretapping statute, to modern web technologies such as pixels, chatbots, and session replay tools. For laboratories, the practical problem is not only the legal uncertainty, but also that small website implementation details, including when tags fire, what free-text inputs are captured, and…