One of the most immediate developments affecting hospitals is a new compliance requirement for off-campus hospital outpatient departments (OPDs) enacted through the FY2026 federal appropriations bill.
Beginning January 1, 2028, hospitals must obtain a unique National Provider Identifier (NPI) for each of its off-campus outpatient departments. Hospitals will also be required to attest that
Early federal enrollment data for the 2026 Affordable Care Act (ACA) marketplace plan year indicates a meaningful decline in coverage following the expiration of enhanced premium tax credits, which may have significant implications for hospitals and providers as coverage affordability pressures grow and payer mix volatility increases.
Enrollment Declines Following Subsidy Expiration
Implementation of the One Big Beautiful Bill Act (OBBBA) continues to reshape Medicaid financing structures across the country. In early 2026, the Centers for Medicare & Medicaid Services (CMS) issued several regulatory actions that operationalize key OBBBA provisions that affect how states fund Medicaid programs and how hospitals receive supplemental payments.
Two developments that are
The Rural Health Transformation (RHT) Program, created under the One Big Beautiful Bill Act (OBBBA), has moved from authorization to implementation with the distribution of the first $10 billion in federal funding for fiscal year 2026 (FY26). The RHT program represents a $50 billion, five-year federal initiative designed to strengthen rural healthcare infrastructure and expand
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
Although much of the public commentary related to the One Big Beautiful Bill Act (OBBBA) has focused on dire predictions that millions will lose coverage, healthcare leaders – including hospital system leaders, compliance teams and finance departments – should pay close attention to the regulatory details of the bill and take proactive steps now to
Our partner Jim Robertson is the featured speaker on the Hospital Finance Podcast episode “Thinking Outside the Box on Challenging State DSH Subsidies,” which is now available online on the Besler website and on major podcast platforms including iTunes, Spotify, Google Podcasts, Stitcher and SoundCloud. Highlights of the episode include a review of the Takings
In the wake of the New Jersey Supreme Court’s 2017 decision in Allstate Insurance Company v. Northfield Medical Center, P.C., management services organizations (MSOs), physicians, private equity funds, and practicing healthcare attorneys should keep the following “do’s and don’ts” in mind when structuring their MSO arrangements to comply with New Jersey corporate practice of medicine
As discussed in this prior blog post, beginning in 2018 the U.S. Department of Health and Human Services (HHS) reduced reimbursement rates for Medicare prescription drugs to 340B hospitals by nearly thirty percent. The American Hospital Association (AHA) filed suit, and on June 15, 2022 the U.S. Supreme Court ruled that the cuts imposed
The United States District Court’s 2021 ruling in Milton S. Hershey Medical Center v. Becerra is one example of a successful legal challenge to federal agency action, but a number of more recent cases reaffirm that lower federal courts may not hesitate to overturn agency action deemed outside the bounds of the agency’s legislative authority.