Publications

On November 20, 2024, CMS published guidance on CAH space sharing arrangements. The guidance acknowledged the importance of providing communities served by CAHs with additional access to health care. Accordingly, CMS expressly permits CAHs to enter into space sharing arrangements, including leases and time-shares, with unrelated non-hospital individuals and entities.  […]

What do SEC football tickets and nail salon outings have in common?  Both were “gifts” to physicians who referred business to a free standing imaging center in a recent settlement.  Outside of health care, such gifts are often a regular part of rewarding clients for their business.  But the federal […]

On the evening of December 23, 2024 the Department of Treasury announced that companies that were created or registered prior to January 1, 2024 and are not otherwise exempt under the Corporate Transparency Act (CTA) from filing a beneficial ownership information report (BOIR) with FINCEN now have until January 13, […]

On December 23, 2024, the Fifth Circuit Court of Appeals issued an order lifting the nationwide preliminary injunction that was previously issued by a federal district court in Texas on December 3, 2024 to suspend enforcement of reporting obligations for millions of businesses under the Corporate Transparency Act (CTA).  Notably, […]

In the absence of a comprehensive federal consumer data privacy law, states have been busy passing legislation that is designed to protect the personal data of their residents and to give some level of control over the use and distribution of that data back to the individual.  2024 was no […]