On March 31, 2026, United Healthcare (“UHC”) successfully moved to dismiss a class action arising from its purported use of third-party tracking technologies on its website. We’ve previously discussed automated tracking on websites, such as by using cookies, pixels, etc., in connection with “trap-and-trace” laws, including at our Health Law […]
Health Law Alert
A Timely Refresh on Ambulatory Surgery Centers and the Federal Anti-Kickback Statute
on Tuesday, 31 March 2026 in
Health Law Alert: Kristin N. Lindgren, Editor
On March 4, 2026, the Office of Inspector General (“OIG”) issued Advisory Opinion No. 26-04 relating to investments in and transfers of ownership interests in an ambulatory surgery center (“ASC”). While most experienced health care administrators understand that the federal Anti-Kickback Statute (“AKS”) applies to ASC arrangements, many do not […]
New Proposed Legislation: H‑1Bs for Physicians and the Healthcare Workforce Act
on Tuesday, 31 March 2026 in
Health Law Alert: Kristin N. Lindgren, Editor
On September 19, 2025, President Trump issued a Presidential Proclamation imposing a new requirement that employers pay a $100,000 fee before sponsoring a foreign worker for H‑1B status. The $100,000 fee applies only to new H‑1B petitions for foreign workers coming directly from abroad and does not apply to individuals […]
Vendor Discounts and the OIG—Where Things Stand After Recent OIG Advisory Opinion
on Friday, 27 February 2026 in
Health Law Alert: Kristin N. Lindgren, Editor
On December 15, 2025, the OIG issued Advisory Opinion No. 25-11 dealing extensively with discounts from vendors. Vendor discounts raise anti-kickback concerns because, on their face, there is remuneration to a customer (in the form of a reduced price or rebate) in exchange for the customer’s purchase of goods or […]
Return of Provider-Based Attestations – What It Means and How to Prepare
on Friday, 27 February 2026 in
Health Law Alert: Kristin N. Lindgren, Editor
On February 3, 2026, the federal government signed the Consolidated Appropriations Act of 2026 (the “Act”) into law. Section 6225 of the Act amends the Social Security Act to bring back the mandatory provider-based attestation (“Attestation”) requirements for off-campus outpatient departments (“Departments”) by the end of 2027. These Attestation requirements […]
