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Fifth Circuit Concurrence Adds Voice to FCA Constitutionality Questions

A first appellate circuit judge has questioned the False Claim Act’s constitutionality. In the Fifth Circuit’s decision last month in United States ex rel Montcrief v. Peripheral Vascular Assocs., P.A., No. 24-50176, — F....more

New Administration Antitrust Push: DOJ, FTC to Identify Anticompetitive Government Regulations and Labor-Related Practices

In recent weeks, the Department of Justice (DOJ) Antitrust Division and Federal Trade Commission (FTC) launched task forces that target potential barriers to competition created by government regulators and private-sector...more

California Legislature Reconsiders Bills Scrutinizing Healthcare Investors

Recently, the California Legislature introduced two bills that may impact private equity healthcare investments in the state, including formalizing corporate practice restrictions and requiring advance notice for certain...more

First Circuit Adopts “But For” AKS Standard, Leaving Third Circuit Alone in Causal-Link Standard

On Feb. 18, 2025, the U.S. Court of Appeals for the First Circuit adopted the “but for” causality standard for violations of the federal Anti-Kickback Statute (AKS) that give rise to violations of the federal False Claims Act...more

CMS Opinion Offers Guidance on Relocation of Physician-Owned Hospitals

On Feb. 26, 2025, McGuireWoods successfully assisted a physician-owned hospital in obtaining a favorable advisory opinion from the Centers for Medicare & Medicaid Services (CMS) regarding its proposal to relocate the entire...more

CMS Nearly Doubles Prior Stark Self-Disclosure Dollar Record in 2024

The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2024 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark...more

Fourth Circuit Upholds OIG Advisory Opinion Process

On January 23, 2025, the United States Court of Appeals for the Fourth Circuit rejected a challenge to Advisory Opinion 22-19 (the “Advisory Opinion”) issued by the United States Department of Health and Human Services,...more

D.C. Circuit Prohibits Pro Se Plaintiffs from Bringing FCA Cases

In United States ex rel. Feliciano v. Ardoin, the D.C. Circuit joined every other circuit to consider the issue, holding that a pro se litigant cannot bring a False Claims Act (FCA) case. The court’s reasoning was...more

Massachusetts Tightens Healthcare Transaction Oversight, Focuses on Healthcare Investors

On Jan. 8, 2025, Massachusetts Gov. Maura Healy signed “An Act Enhancing the Market Review Process” (the Act). The Act increases regulatory reporting obligations and oversight of healthcare transactions involving private...more

Second Circuit Joins Other Circuits with AKS One Purpose Test

On December 27, 2024, the United States Court of Appeals for the Second Circuit decided United States ex rel. Camburn v. Novartis Pharmaceuticals Corporation and joined a growing list of federal circuit courts that have...more

OIG Recommends Increased RPM Oversight

On September 24, 2024, the Department of Health and Human Services Office of Inspector General (“OIG”) published a report (the “Report), reviewing and recommending increased oversight of remote patient monitoring (“RPM”)...more

Key Takeaways From the 2024 Healthcare Finance and Growth Conference

Over 200 fellow healthcare leaders joined the 17th Annual Healthcare Finance and Growth conference for interactive programming discussing the latest developments in the industry and the challenges the industry faces in 2024...more

Ounce of Prevention: Are You Providing Free Auxiliary Aids and Services to Individuals With Disabilities?

Applicable Provider Types: All - Is Your Entity in Compliance? Recent regulatory language makes clear that most healthcare providers must provide free auxiliary aids and services for patients with disabilities....more

Stark Law Regulations Under the Microscope in a Post-Chevron World

Recently, in United States ex rel. Kyer v. Thomas Health Systems, the judge overseeinga whistleblower’s False Claims Act (FCA) suit against Thomas Health Systems Inc. stalled further decisions until both parties could file...more

Ounce of Prevention: Do You Know When Your DMEPOS Surety Bonds Expire?

Applicable Provider Types: Any individual or entity that receives Medicare reimbursement for selling or renting DMEPOS - Is Your Entity in Compliance? Most durable medical equipment, prosthetics, orthotics and...more

Ounce of Prevention: Are You Providing Free Translators for Individuals with Limited English Proficiency?

Applicable Provider Types: All - Is Your Entity in Compliance? Recent regulatory language makes clear that most healthcare providers must provide free translators or interpreters for patients with limited English...more

Ounce of Prevention: Are All Locations Where You Dispense DMEPOS Individually Enrolled in Medicare?

Applicable Provider Types: Any individual or entity that receives Medicare reimbursement for selling or renting DMEPOS...more

CMS 2025 Payment Proposals Could Impact Cardiology

The Centers for Medicare & Medicaid Services (CMS) recently published two proposed rules that could affect Medicare reimbursement for cardiology services. On July 22, 2024, CMS published the Calendar Year (CY) 2025 Hospital...more

Texas Federal District Court Sets Aside FTC’s Non-Compete Rule Nationwide

A Texas federal district court held on Aug. 20, 2024, that the Federal Trade Commission’s rule banning most employer-employee non-compete agreements is unlawful. This decision — unlike earlier preliminary decisions — orders...more

Texas District Court Preliminarily Enjoins FTC’s Non-Compete Rule Only for Named Plaintiffs

The Federal Trade Commission (FTC) issued a final rule on April 23, 2024, that would ban most employer-employee non-compete agreements. That same day, a challenge to the rule was filed in the U.S. District Court for the...more

Ten Action Items for Healthcare Portfolio Companies in 2024

The investor-backed provider community may be feeling pressure and facing scrutiny from various angles in 2024, as federal and state agencies implement complex pre-closing review processes for healthcare transactions from an...more

A View From the Top: Matt Devine of Allied Health Management Services Organization

The interview below is part of a McGuireWoods series featuring interviews with C-suite leadership of private equity-backed portfolio companies. To recommend a leader for a future interview, email Holly Buckley at...more

Key Takeaways From the 2024 Healthcare Private Equity and Finance Conference

McGuireWoods recently held its 20th Annual Healthcare Private Equity and Finance Conference (HCPE Conference) in Chicago. The conference drew more than 1,000 professionals from private equity funds, senior and mezzanine...more

Eight Healthcare Provider Requirements From Updated Section 1557 Nondiscrimination Rule

On May 6, 2024, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) and the Centers for Medicare & Medicaid Services (CMS) published their final rule on nondiscrimination in the Federal Register...more

FAQs: An Essential Guide for Healthcare Leaders Navigating FTC’s Non-Compete Ban

The Federal Trade Commission’s April 23 final rule banning most non-competes for workers in the United States, including clinical and non-clinical employees in the healthcare industry, undoubtedly will raise questions from...more

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