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    CMS Imposes Moratorium on Home Health and Hospice Enrollment: Scope and Legal Mechanics of the Moratorium

    June 24, 2026

    In May 2026, the CMS announced a six-month, nationwide moratorium on new Medicare enrollment for HHAs and hospice providers. It is the third nationwide Medicare enrollment moratorium imposed by the current administration and the second in 2026. This article examines the scope and legal mechanics of the moratorium, its implications for healthcare transactions, and the industry reaction to the action. On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) announced a six-month, nationwide moratorium on new Medicare enrollment for home health agencies (HHAs) and hospice providers, effective immediately.[1] The moratorium, implemented in coordination with Vice President JD…

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    OIG Clarifies AKS Liability Beyond FMV and Stark Law: Additional Guidance Provided on Physician Remuneration

    June 10, 2026

    On April 23, 2026, the U.S. Department of HHS OIG updated its General Questions Regarding Certain Fraud and Abuse Authorities FAQ page. The update revised one existing FAQ and added another. This article discusses the OIG’s updated guidance and its implications for parties that rely on FMV opinions in structuring healthcare arrangements. On April 23, 2026, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) updated its General Questions Regarding Certain Fraud and Abuse Authorities Frequently Asked Questions (FAQ) page for the first time since July 2024.[1] The update revised one existing FAQ and added…

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    Management Services Agreements

    June 27, 2018

    This article briefly discusses the current trends in the practice management industry, as these trends may directly and indirectly affect both the management company and the healthcare entity. This overview of the services provided by practice management groups, is followed by a discussion of the competitive, reimbursement, regulatory, and technological environments in which practice management groups operate.