New Jersey advanced practice nurses (“APNs”) and physician assistants (“PAs”) have until April 2, 2026, to secure collaborating or supervising physicians before pandemic-era practice waivers expire. Healthcare practices and providers should take steps now to ensure compliance. Background On March 9, 2020, former New Jersey Governor Phil Murphy signed Executive Order 103 (“EO 103”), declaring... Continue Reading…More

Florida has fundamentally shifted the compliance landscape for patient credit balances. With the enactment of CS/CS/SB 1808 (Refund of Overpayments Made by Patients), health care facilities and practitioners are now under a strict statutory mandate to refund patient overpayments within thirty days of determination, with enforcement through administrative fines and professional discipline. The law takes... Continue Reading…More

E.J. Cyran, Healthcare Lawyer and Partner at Fox Rothschild LLP, recently guested on PracticeCare®, a podcast devoted to help private practice owners stay private. The topic of the episode may be a surprising one for physicians, dentists and other healthcare providers–when private equity shows interest in your practice or your facility, think about expanding and... Continue Reading…More

In October 2025, Governor Gavin Newsom signed two sweeping laws that significantly reshape how healthcare transactions are reported and how private equity groups and hedge funds may engage with physician and dental practices. Assembly Bill 1415 (AB 1415) establishes new reporting obligations for healthcare transactions involving material changes in ownership or control, while Senate Bill... Continue Reading…More

Office of Inspector General (“OIG”) Advisory Opinion 25-09[1] addresses an inquiry from a company that develops, manufactures and sells medical devices used in emergency stroke treatment and provides commentary for similarly situated business looking to navigate potentially complicated investor situations. The company in question requested this opinion to determine whether the below-described arrangement would be... Continue Reading…More

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Effective July 1, 2025, Florida is implementing a significant change to its healthcare licensure framework. A new law, enacted through Florida’s House Bill 975, dramatically expands the scope of required background screening for licensed healthcare practitioners. This is a major update that will affect a broad range of healthcare professionals and the organizations that employ... Continue Reading…More

A recent federal court decision has vacated the CFPB’s Medical Debt Rule, restoring the previous framework under the Fair Credit Reporting Act (FCRA). Credit reporting agencies can continue to include coded medical debt in consumer reports, and creditors may consider this information when making credit decisions. Healthcare providers should ensure compliance with FCRA requirements and stay alert for future regulatory changes, especially as some states continue to pursue their own medical debt reporting laws. Continue Reading…More

E.J. Cyran, Healthcare Lawyer and Partner at Fox Rothschild LLP, recently guested on PracticeCare®, a podcast devoted to help private practice owners stay private. The topic of the episode was identifying and avoiding landmines in agreements between private practices and other healthcare providers. You can listen to the episode on Apple or Spotify here: https://marketvisorygroup.com/podcast/e-j-cyran-on-landmines-in-agreements-with-other-healthcare-providers/ Contact E.J. Cyran at ecyran@foxrothschild.com or (610) 458-4963. Continue Reading…More

Florida’s healthcare providers and their insurers are on the verge of a significant adjustment to the state’s medical malpractice landscape. For over three decades, a controversial provision within Florida’s medical malpractice laws limited who could file a wrongful death lawsuit involving non-economic damages, such as pain and suffering. With the passage of House Bill 6017... Continue Reading…More

What better way to welcome the new year than with proposed new HIPAA Security Rules?  As 2024 came to an end, the U.S. Department of Health and Human Services announced new proposed regulations to strengthen cybersecurity and protection measures for ePHI.  If adopted, this would be the first update to the Security Rule since 2013. ... Continue Reading…More

Our colleague Amy Perry, who writes for the firm’s Health Law Matters blog, has posted a timely update on the Department of Health and Human Services’ new reproductive health care rules, which will go into effect on December 23, 2024. The underlying goals of these rules are to ensure individuals do not forego lawful health care... Continue Reading…More

The American Privacy Rights Act of 2024 (APRA), a bipartisan and “historic” comprehensive data privacy bill unveiled April 8, 2024, would preempt state data privacy laws and be enforced by the Federal Trade Commission, states, and affected individuals. As per the Press Release: “This comprehensive draft legislation sets clear, national data privacy rights and protections for... Continue Reading…More

Today the U.S. Department of Health & Human Services (HHS) finalized rules published in December of 2022 changing the requirements for handling SUD patient information governed by 45 CFR part 2 (Part 2). Health care facilities subject to Part 2 often struggled to comply with requirements related to SUD patients and their information that were... Continue Reading…More

Exactly 12 days before Christmas, the U.S. Department of Health and Human Services’ Office of the National Coordinator (ONC) gave the health industry a unique gift buried in a 900+ page rule adoption. The gift?  The first comprehensive U.S. regulation delineating the responsible use and oversight of AI used in connection with health care decision-making.... Continue Reading…More

On November 6, 2023, the HHS Office of Inspector General published a new compilation of compliance guidance under the title General Compliance Program Guidance (GCPG) for the healthcare compliance community and other health care stakeholders. Consistent with the OIG’s April 24, 2023 announcement of its plan to issue modernized, improved, and accessible guidance, the 91-page document is now... Continue Reading…More

Disregard your Health Insurance Portability and Accountability Act obligations at your own risk.  That’s the stark warning covered entities and business associates should take away from a recent settlement entered into by the nation’s largest publicly operated health plan and the U.S. Department of Health and Human Services’ Office for Civil Rights. Click here to... Continue Reading…More

Last week, the Federal Trade Commission (“FTC”) and the U.S. Department of Health and Human Services’ Office for Civil Rights (“OCR”) issued a joint letter (“Joint Letter”) (https://www.ftc.gov/system/files/ftc_gov/pdf/FTC-OCR-Letter-Third-Party-Trackers-07-20-2023.pdf) to approximately 130 hospitals and telehealth providers, warning that online tracking technologies integrated into their websites and/or mobile apps may be improperly disclosing personal health data to third... Continue Reading…More

Brightree by ResMed (“Brightree”), a cloud-based management software platform for healthcare providers, has conducted its biannual interoperability survey, and issued its corresponding biannual Interoperability and Engagement Research Report. Most notably, and not surprisingly, 99% of the 400+ provider entities that were surveyed, said they are most likely to send patient referrals for post-acute care (PAC)... Continue Reading…More

Privacy, data security and regulatory compliance affect companies in every industry. Join leading privacy professionals at our fifth annual Privacy Summit as they discuss some of the most consequential topics of the day during the following panels: The Summit will feature a Fireside Chat with Sue Vinci, Chief Privacy Officer of Verizon. She and Elizabeth Litten,... Continue Reading…More