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The Hart-Scott-Rodino Antitrust Improvements Act of 1976 (“HSR Act”), as amended, requires all persons contemplating certain mergers or acquisitions that meet or exceed the jurisdictional thresholds (shown below) to file a premerger notification (an “HSR Filing”) with the Federal Trade Commission (“FTC”) Premerger Notification Office and the Department of Justice (“DOJ”) Antitrust Division and to wait a period of time before consummating the transaction.

Each fiscal year, the jurisdictional filing thresholds are adjusted to reflect the percentage change in…
Continue Reading FTC Announces Annual Hart-Scott-Rodino Premerger Notification Filing Thresholds Increase for 2026

Health care organizations planning major capital projects, such as hospital expansions, surgical centers and outpatient facilities, often face familiar frustrations: delays, cost overruns, redesign cycles and coordination breakdowns. Traditional delivery models like design‑bid‑build or construction manager‑at‑risk can unintentionally reinforce silos. Integrated Project Delivery Agreements (“IPDA”) offer a collaborative alternative designed to align incentives, reduce waste and improve project performance.
What Is an IPDA?
An IPDA is a single, multi‑party contract that binds the owner, architect, contractor and key consultants…
Continue Reading From Silos to Synergy: Integrated Project Delivery Agreements for Today’s Health Care Facilities

What to know if childbirth recovery, postpartum depression, or anxiety keeps you from returning to work
Pregnancy and childbirth are often described as joyful milestones—but they can also bring unexpected medical challenges. For many working parents, short-term disability (STD) insurance provides critical income replacement during pregnancy and recovery after birth. Unfortunately, people are often unaware that disability benefits don’t have to end simply because the “standard” recovery period has passed. When complications arise, benefits can frequently be extended, and…
Continue Reading Short-Term and Long-Term Disability Benefits for Pregnancy and Postpartum Complications

The health care transactional landscape may have been quieter than anticipated at the beginning of 2025, with providers experiencing financial strains, but the year finished out with a high level of activity, marked by opportunistic growth strategies. Transactions will continue to be anything but “cookie-cutter.” In this article, we highlight eight M&A trends demonstrating how the financial landscape, regulatory considerations, cross-disciplinary strategies and market disruptors shaped deals in 2025 and how these same factors will continue to impact deals…
Continue Reading Bottom Line: Health Care Transactions Are More Bespoke Than Ever – Lessons Learned from 2025 and What’s to Come in 2026

We frequently get calls from hospital systems, health care providers and investors regarding negotiating on-campus ground leases. They are certainly unique. Here are 10 business points to consider when negotiating on-campus ground leases.

  • Premises – The land being leased can vary widely. We often see hospitals ground leasing only the footprint of the building. There are some instances, on larger campuses, where the hospital allows the developer to lease the land needed for the footprint of the building, plus

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    Continue Reading Weekly Hospital Real Estate Briefing: 10 Tips for Negotiating On-Campus Ground Leases

    Health care employment professionals face an all-too-familiar challenge entering 2026: keeping pace with a patchwork of state employment laws that show no signs of slowing down. The employment law landscape continues to evolve rapidly, presenting health care employers with new compliance challenges. Outlined below are just a few of the key legal trends impacting the health care HR landscape this year.
    Paid Family Leave Programs and Expansion
    State-level paid family and medical leave programs are growing in popularity across…
    Continue Reading Legal Trends Impacting Health Care Human Resources in 2026

    Hall Render is pleased to announce that Susan James has joined the Firm. With over three decades of dedicated experience, Susan James advises a broad range of health care industry clients on complex legal, operational, strategic and governance matters. Susan represents hospitals, health systems, physicians, physician group practices, ambulatory surgery centers and physician-owned hospitals. She enjoys navigating the complex and constantly evolving health laws and regulations while offering practical solutions to her clients.
    Susan counsels clients on compliance with…
    Continue Reading Susan James Joins Hall Render

    On December 9, 2025, the Department of Health and Human Services’ (“HHS”) Office of the Inspector General (“OIG”) issued its annual solicitation for proposals and recommendations for developing new or modifying existing Anti-Kickback Statute (“AKS”) safe harbor provisions. In doing so, the OIG’s objective is to identify safe harbors that safeguard “beneficial and innocuous arrangements” and to protect federal health care programs and their beneficiaries from “the harms caused by fraud and abuse.” The solicitation also seeks proposals for…
    Continue Reading OIG Solicits Proposals for the Development and Modification of Anti-Kickback Statute Safe Harbors and Special Fraud Alerts

  • Health systems and physician groups largely held back on mergers and acquisitions in 2025 due to inflation, high labor costs, reimbursement uncertainty and new state laws targeting private equity. In 2026, deal activity is expected to increase as policy uncertainty clears up and health systems align with physicians to grow their ambulatory networks.
  • PE firm IRA Capital announced the acquisition of a 24-MOB portfolio with 1.5M sf of space across 11 states. The assets are largely on-campus or adjacent,

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    Continue Reading Weekly Hospital Real Estate Briefing

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    The Centers for Medicare & Medicaid Services (“CMS”) continues to scrutinize beneficiary transparency, medical necessity and data‑driven oversight of hospital billing and utilization. This scrutiny means continued compliance risk for hospitals. Two long‑standing compliance tools remain especially relevant for hospital leadership: the Medicare Outpatient Observation Notice (“MOON”) and the Program for Evaluating Payment Patterns Electronic Report (“PEPPER”). Recent CMS communications reaffirm expectations related to proper MOON delivery and highlight PEPPER as an active monitoring mechanism hospitals should be using…
    Continue Reading Medicare Outpatient Observation Notice and PEPPER Reports: Key Compliance Considerations

    On December 29, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced the first round of awards under the Rural Health Transformation Program (“RHTP”), a $50 billion, five-year initiative intended to strengthen and modernize health care delivery in rural communities nationwide. All 50 states will receive funding beginning in Federal Fiscal Year (“FFY”) 2026, with first-year awards averaging $200 million per state.

    At the same time, CMS formally established the Office of Rural Health Transformation within the Center…
    Continue Reading CMS Announces $50 Billion Rural Health Transformation Program Awards to All 50 States

    We hope everyone enjoyed some time off over the holidays. As we reflect on 2025 and head into the new year, we spent some time mapping out our hospital real estate predictions for 2026. We believe it will be a mixed bag for hospitals and health systems around the country. Most hospital systems will face financial headwinds, which will result in cost-cutting measures. Those headwinds also create opportunities for strategic growth for those with strong balance sheets or in…
    Continue Reading Weekly Hospital Real Estate Briefing: Our 2026 Predictions

    On Tuesday, December 30, 2025, the Drug Enforcement Administration (“DEA”) and the Department of Health and Human Services (“HHS,” and together with the DEA, the “Agencies”) issued a fourth temporary rule (the “Fourth Temporary Rule”) extending the COVID-19-era telemedicine flexibilities for prescribing Schedule II–V controlled substances  through December 31, 2026. The extension allows DEA-registered practitioners to continue prescribing controlled medications via telemedicine without a prior in-person visit, subject to existing safeguards and state law. The Fourth Temporary Rule notes…
    Continue Reading DEA and HHS Announce Fourth Extension of COVID-Era Telemedicine Flexibilities for Controlled Substance Prescribing

    Under the federal Stark Law (the “Stark Law”), hospitals, physician groups, labs and other provider entities may provide non-monetary (i.e., non-cash or cash-equivalent) compensation to physicians up to an aggregate amount of $535 for calendar year 2026. The dollar limit for “medical staff incidental benefits” provided by a hospital to a member of its medical staff (e.g., meals, parking and other items or incidental services that are used on a hospital’s campus) is less than $46 per occurrence. Other…
    Continue Reading 2026 Non-Monetary Compensation to Physicians (and Chance to Review 2025)

  • Revista published a pair of interesting blog posts: (1) the amount of general hospital space under construction in Q3 of 2025 has continued a multi-year climb that started in 2022; and (2) noting that the least expensive MOB rents (bottom 10th percentile) have grown at just 1.3%/yr since 2018, while moderately priced properties (50th percentile base rent) have grown at 1.7%/yr and the most expensive properties (90th percentile base rents) have grown 2.7%/yr over the same period.
  • At a

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    Continue Reading Weekly HRE Briefing, Dec. 24, 2025

    Until this year, the Food and Drug Administration’s (FDA or agency) Office of Prescription Drug Promotion (“OPDP”) enforcement activity had settled into a relatively predictable pattern. In both 2023 and 2024, OPDP issued five enforcement letters each year, reinforcing a perception that the agency was exercising restraint and directing its limited resources toward more complex promotional claims, particularly those in patient-facing materials. However, that perception shifted dramatically in September 2025, when OPDP released nearly 100 enforcement letters (both…
    Continue Reading A Turning Point for OPDP: What 2025 Enforcement Activity Signals for 2026