By paring back on the broad entity level GLBA exemption, Montana and Connecticut have joined California, Minnesota, and Oregon as states that do not include a broad entity level GLBA financial institution exemption within their respective consumer data privacy laws. Montana On May 8, Montana Governor Greg Gianforte signed Senate […]
Publications
Nebraska Supreme Court Rejects Effort to Undermine the Enforceability of Personal Guaranties
Henderson State Company v. Garrelts, 319 Neb. 485 (2025) On July 18, 2025, the Nebraska Supreme Court issued a decision enforcing the plain language of two personal guaranties of bank loans. The decision rejected the effort of the guarantors to impose obligations on the lending bank beyond those contained in […]
The Medicare Shared Savings Program in the Trump Era
Many providers have made substantial investments in ACOs for participation in the Medicare shared savings program. As the Trump Administration makes significant changes to many government programs, many have questioned how the Administration will view this program. That concern was stoked by an announcement in March that four smaller CMS […]
A Boomerang Effect: Recent Regulatory Changes Involving Reproductive Health Care
Recent legal and regulatory changes around reproductive health care are creating a boomerang effect for the health care industry. On June 18, 2025, the U.S. District Court for the Northern District of Texas issued an order vacating the majority of the HIPAA Privacy Rule to Support Reproductive Health Care Privacy […]
2024 MHPAEA Rule: Enforcement Halted, Parity in Limbo
Establishing Equal Footing: The Mental Health Parity and Addiction Equity Act Enacted in 2008, the Mental Health Parity and Addiction Equity Act (“MHPAEA” or the “Act”) aims to ensure that coverage for mental health or substance use disorders (“MH/SUD”) isn’t more restrictive than coverage for medical or surgical care. Simply […]