Since the enactment of the One Big Beautiful Bill Act (OBBBA) in mid-2025, the healthcare industry has been navigating a period of accelerated policy change affecting coverage, reimbursement, and care delivery. As the implementation of OBBBA-authorized funds continues, the data offers insights into how the law is reshaping the healthcare landscape at both the national and state levels.

Against this backdrop, President Trump recently unveiled a new policy framework, the Great Healthcare Plan, and on February 5, 2026, signed a fiscal year 2026 appropriations bill introducing significant operational and reimbursement implications for hospitals that will interact directly with both OBBBA implementation and future reform efforts. For hospitals and providers, these developments arrive at a moment of heightened financial and operational sensitivity, particularly as payer mix volatility and underinsurance concerns continue to grow.

Our healthcare team will continue to examine the early implementation of the OBBBA and related federal healthcare policy developments shaping the healthcare landscape and will address various aspects of those developments in future posts on this blog.

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Photo of Sukrti Thonse Sukrti Thonse

Associate, Corporate and Healthcare

Sukrti supports the firm’s representation of clients in corporate transactions and in legal matters related to the healthcare sector, with experience across all stages of the corporate life cycle.

Her work includes the formation of corporate entities, including capitalization…

Associate, Corporate and Healthcare

Sukrti supports the firm’s representation of clients in corporate transactions and in legal matters related to the healthcare sector, with experience across all stages of the corporate life cycle.

Her work includes the formation of corporate entities, including capitalization structures, fundraising, financing, strategic issues, and negotiations with investors. She provides support related to merger and acquisition transactions, venture capital financings, public offerings, regulatory due diligence reviews, private equity investments, regulatory disclosures in securities filings, and transactions involving FDA-regulated entities. She also assists clients with issues related to corporate governance and day-to-day business operations.

Sukrti has developed expertise related to HIPAA compliance and other healthcare privacy issues. She provides guidance on regulatory frameworks, including those associated with FDA regulations, the Anti-Kickback Statute, Stark Law, and other healthcare compliance concerns.

Contact information:

sthonse@greenbaumlaw.com | 732.476.2480 | vCard

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

Read more about Sukrti ThonseSukrti's Linkedin Profile
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Photo of James A. Robertson James A. Robertson

Partner and Chair, Healthcare

Jim’s healthcare practice is reflective of his significant expertise across a wide range of legal disciplines, enabling him to effectively counsel clients on a myriad of healthcare regulatory, corporate and litigation matters. He represents a diverse array of healthcare…

Partner and Chair, Healthcare

Jim’s healthcare practice is reflective of his significant expertise across a wide range of legal disciplines, enabling him to effectively counsel clients on a myriad of healthcare regulatory, corporate and litigation matters. He represents a diverse array of healthcare industry clients including for-profit and not-for-profit healthcare and hospital systems, academic medical centers, nursing homes, home health agencies, medical device manufacturers, pharmaceutical companies, integrated delivery networks, physicians and physician practice groups, and healthcare private equity funds.

Jim provides comprehensive representation in connection with all types of healthcare transactions, including corporate mergers and acquisitions, joint ventures, and divestitures. He assists clients with the structuring and creation of clinically integrated networks (CINs), organized delivery systems (ODSs), accountable care organizations (ACOs), multiple employer welfare arrangements (MEWAs), and health insurance companies. He oversees the establishment and purchase/sale of individual physician and group practices, ambulatory surgery centers, nursing homes, and assisted living facilities. He structures and negotiates compensation arrangements with physicians in connection with employment and exclusive contracting arrangements, medical directorships, physician recruitment initiatives, hospital department management, office and equipment leases, and management services arrangements. He also negotiates managed care agreements and risk-sharing arrangements with payors and represents healthcare clients in payor litigation.

On the regulatory and compliance fronts, Jim regularly provides guidance on issues related to fraud and abuse laws, including the federal Anti-Kickback Statute and Stark Law, the New Jersey Codey Law, the certificate of need statute and Community Healthcare Asset Protection Act (CHAPA), as well as other regulatory compliance issues associated with healthcare transactions and physician-integration arrangements. He develops, implements, and maintains corporate compliance programs for hospitals and other providers in the healthcare industry and is well-versed in the compliance issues associated with, and the implementation of requirements under, the Health Insurance Portability and Accountability Act (HIPAA), the Emergency Medical Treatment and Labor Act (EMTALA), and the Affordable Care Act (ACA).

In the area of information privacy and data security, Jim advises healthcare clients on issues arising under HIPAA and the Health Information Technology for Economic and Clinical Health Act (HITECH). This includes the drafting and negotiation of HIPAA compliant business associate agreements with third party vendors, drafting and assisting in the enforcement of privacy and security policies within client organizations, and providing guidance on record retention requirements and the physical or electronic storage of medical records. In addition, he represents healthcare clients in investigating, reporting, and remediating information breaches and the liability such breaches create under various information privacy and security laws.

Jim assists clients in seeking advisory opinions from federal and state regulatory agencies, and regularly represents healthcare entities in Medicare, Medicaid, charity care, graduate medical education (GME) and disproportionate share hospital (DSH) reimbursement matters before state administrative agencies and the federal Provider Reimbursement Review Board. His work also encompasses internal audits and investigations, responding to government inquiries, investigations, subpoenas and search warrants, and providing advice in connection with voluntary self-disclosures and corporate integrity agreements (CIAs).

Jim is a resource for addressing medical staff matters, providing counsel on fair hearing requirements and designing state-of-the-art medical staff bylaws. He also provides guidance in connection with strategic initiatives on system affiliations including the establishment of outpatient health care offices, diagnostic imaging facilities and ambulatory surgery centers.

Contact information:

jrobertson@greenbaumlaw.com | 973.577.1784 | vCard | LinkedIn

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

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