On July 29, 2026, the Department of Justice (“DOJ”) announced that it declined to bring criminal charges against Campus Eye Management Holdings LLC and its subsidiary, Campus Eye Management LLC (collectively “Campus Eye”), a New Jersey-based management services organization. Campus Eye is the first healthcare company to avoid criminal prosecution under the DOJ’s new corporate
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CMS Proposes Provider Enrollment Changes to Strengthen Program Integrity
On July 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its Calendar Year 2027 Home Health Prospective Payment System Proposed Rule (the “Proposed Rule”) in the Federal Register, which includes several provider enrollment changes that would be applicable to all provider and supplier types. In its efforts to strengthen program integrity, CMS
OIG Clears Pathway for Free Supplemental Cancer Screening Report
On May 15, 2026, the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 26-11 (the “Opinion”), a favorable opinion for a proposed arrangement that involved providing patients a free supplemental cancer screening report (the “Proposed Arrangement”). The Opinion provides guidance for healthcare companies navigating the
HHS Inspector General Reminder: Kickback Liability Turns on Intent, Not Market Value or Stark Law Compliance
The U.S. Department of Health and Human Services Office of Inspector General (OIG) updated its FAQs on Fraud and Abuse Authorities to add a new answer on fair market value (FMV) in FAQ 17 and revise the answer on how the physician self-referral law (Stark Law) overlaps with the federal Anti-Kickback Statute (AKS) in FAQ
Long Anticipated Medicare Advantage Compliance Guidance Heightens Investor and Provider Scrutiny
In February 2026, the Department of Health and Human Services, Office of Inspector General (HHS-OIG) issued its highly anticipated Industry Compliance Program Guidance for Medicare Advantage (MA ICPG), the first such compliance guidance for the MA industry in over 25 years. The MA ICPG is the second industry segment-specific compliance guidance published in a series
CMS Reaches $100 Million in Stark Self-Disclosure Settlements
The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2025 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark Law). Generally, two notable items arise from our annual review of CMS’ settlement data. First, CMS has now reported aggregate settlements reaching $105,090,031.
Ninth Circuit Ruling in FCA Case Predicated on 340B Pricing Violations Has Significant Implications for Pharma Manufacturers
On March 17, 2026, the United States Court of Appeals for the Ninth Circuit issued a significant opinion in United States ex rel. Adventist Health System of West v. AbbVie Inc., [1] reversing the district court’s dismissal of a qui tam complaint brought under the False Claims Act (“FCA”) against four major drug manufacturers. The
HHS OIG Issues Guidance on Anti-Kickback Statute Implications for Direct-to-Consumer Drug Sales Ahead of TrumpRx Launch
In advance of the anticipated rollout of the “TrumpRx” website, a platform promising lower-priced drugs sold directly to consumers, the Office of Inspector General of the Department of Health and Human Services released a special advisory bulletin on Jan. 27, 2026, outlining the Federal Anti-Kickback Statute implications for direct-to-consumer drug sales. The OIG concludes that
OIG Solicits Proposals for AKS Safe Harbors and Special Fraud Alerts
The Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) is accepting public proposals for new or modified safe harbor provisions under the Federal Anti-Kickback Statute, as well as recommendations for new Special Fraud Alerts. The deadline to submit ideas is 5 p.m. ET on February 9, 2026.
OIG Issues Remote Patient Monitoring Report: Billing Pitfalls and Compliance Risks
On August 25, 2025, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) issued a report analyzing Medicare billing practices for remote patient monitoring (“RPM”) services during 2024. As RPM technologies have matured and become more accessible, their availability has driven widespread adoption and enhanced patient care by enabling continuous, data-informed