The Illinois Department of Revenue (“IDOR”) has announced the 2025 Illinois Tax Amnesty Program (the “Program”), authorized by the Illinois Tax Delinquency Amnesty Act. This limited-time program offers taxpayers a valuable opportunity to pay Eligible Tax Liabilities and have penalties and interest forgiven on taxes paid in full during the amnesty period, which runs from October 1, 2025, through November 17, 2025 (the “Amnesty Period”).
Eligible Tax Liabilities
The Program applies to most IDOR‐administered taxes, including individual and corporate
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Weekly Hospital Real Estate Briefing
USCIS Clarification on Restriction on Entry of Certain Nonimmigrants
This client alert provides updates on our previous guidance related to the September 19, 2025, Presidential Proclamation (the “Proclamation”), Restriction on Entry of Certain Nonimmigrant Workers. On October 20, 2025, U.S. Citizenship and Immigration Services (“USCIS”) published updated guidance on the applicability of the Proclamation. The update clarifies:
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Medicaid Developments Unrelated to Recent Congressional Actions
Recent weeks and months have witnessed several Medicaid developments that may significantly impact Medicaid funding across the country. Not all of these developments are related to the Medicaid-related provisions of H.R. 1 (Public Law 119-21 (July 4, 2025), otherwise known as the “One Big Beautiful Bill”). This article summarizes three developments that are unrelated to H.R. 1:
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Indiana Court of Appeals Emphasizes Trial Court’s Role in Credibility Determinations for Grave Disability Findings
The Indiana Court of Appeals (the “Court”) in In re: the Civil Commitment of J.A. upheld the trial court’s Order for Temporary Commitment, holding sufficient evidence supported the trial court’s finding that J.A. was gravely disabled and unable to function independently outside of the hospital setting. In re: the Civil Commitment of J.A., No. 25A-MH-528, 260 N.E.3d 231 (Ind. Ct. App. 2025). The Court also emphasized it would not reweigh evidence or assess witness credibility on appeal, despite J.A.’s
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OPO Landscape Series: Shutdown Stalls Organ Transplant Oversight
In a notable move, the Department of Health and Human Services (“HHS”) has directed the Organ Procurement and Transplantation Network (“OPTN”) to suspend some routine oversight activities during the ongoing government shutdown. In early October 2025, it was reported that HHS directed the United Network for Organ Sharing (“UNOS”)—the nonprofit contractor that operates the OPTN—to pause certain compliance and policy functions. UNOS responded by canceling some committee meetings and pausing its monitoring of reports on heart and lung transplant
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Weekly Hospital Real Estate Briefing: Federal “Stop MPT Act” Aims to Ban Sale-Leasebacks | Hospital-at-Home Programs in Limbo | Indiana Hospitals Brace for Medicaid Reduction
Indiana Court of Appeals Holds Hospital Recidivism Coupled with Medication Noncompliance May Establish Grave Disability
The Indiana Court of Appeals (the “Court”) in In re Commitment of G.J. emphasized the significance of hospital recidivism and catatonia as evidence and upheld the trial court’s Order for Temporary Commitment. No. 24A-MH-3101, 2025 WL 2438216 (Ind. Ct. App. 2025).
Background
G.J., diagnosed with schizophrenia, presented with symptoms of catatonia and periods of psychosis. She initially stated she would continue taking her medication outside the hospital, but also expressed she did not believe she needed medication. Although G.J.
Continue Reading Indiana Court of Appeals Holds Hospital Recidivism Coupled with Medication Noncompliance May Establish Grave Disability
Weekly Hospital Real Estate Briefing: ASC Volumes Continue to Expand | 30% of Telemed Visits Paused During Shutdown | Intermountain Expands Outpatient Imaging Chain in WA
FL District Court Extends the Indirect Purchaser Rule to Civil RICO Claims and Ultimately Dismisses Insurance Company’s RICO Claim Against Pharmaceutical Manufacturer
In Humana Inc. v. Teva Pharmaceuticals USA, Inc., the District Court for the Middle District of Florida (the “Court”) dismissed claims brought by Humana under the Racketeer Influenced and Corrupt Organizations Act (“RICO”) against Teva Pharmaceuticals USA and a few specialty pharmacies (collectively, “Teva”). The Court ruled that Humana lacked standing to sue due to the indirect purchaser rule. Despite the case’s dismissal, it’s important for hospitals and health care providers to focus on compliance with payors as
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In-Focus Review of OIG’s Unfavorable Advisory Opinion Regarding Third-Party Portal Access Fees
Recently, the Department of Health and Human Services Office of Inspector General (“OIG”) issued Advisory Opinion 25-08 (the “Advisory Opinion”), which addressed whether a proposed arrangement involving a medical device manufacturer’s payment of access fees to a third-party vendor’s billing portal (“Proposed Arrangement”) would violate the federal Anti-Kickback Statute (“AKS”). Based on the facts provided, the OIG declined to issue a favorable opinion and concluded that the Proposed Arrangement would pose a high risk of fraud and abuse if
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Zachary Renier Joins Hall Render
Hall Render is pleased to announce that Zachary Renier has joined the Firm in its Milwaukee office.
Zachary focuses his practice on health information technology and advising clients on privacy and data security requirements, including HIPAA, Information Blocking and associated state data use and data privacy laws. Zachary assists clients with issues involving electronic health records, telemedicine, e-commerce and the responsible use of artificial intelligence. Additionally, he has experience reviewing data use and health information sharing contracts and providing
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Ninth Circuit Age Discrimination Case Reiterates Importance of Promotion Policies
On October 3, 2025, the Ninth Circuit issued an opinion reversing the district court’s decision granting summary judgment on an age discrimination lawsuit filed by three plaintiffs against Circle K. Circle K had won the case on summary judgment, with the district court’s opinion based largely on the fact that the three plaintiffs had not applied for the director position at issue and thus could not establish a prima facie case of age discrimination, because a necessary element of
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Weekly Hospital Real Estate Briefing: $48M PILOT Deal with Hospitals and Universities in Baltimore | Clarksville Population Growth Attracts New Hospitals | Regional One Announces Location of New Academic Medical Center
NADOHE v. Trump Update: Oral Arguments Suggest Anti-DEI Executive Orders May Survive Legal Challenge
The Fourth Circuit Court of Appeals (“Fourth Circuit”) recently heard oral arguments in National Association of Diversity Officers in Higher Education v. Donald Trump (“NADOHE v. Trump”), a case challenging the constitutionality of certain aspects of President Trump’s anti-diversity, equity and inclusion (“DEI”) executive orders, including Executive Order 14151, Ending Radical and Wasteful Government DEI Programs and Preferencing, and Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (collectively, the “EOs”). The Fourth Circuit previously granted
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Weekly Hospital Real Estate Briefing – Sept. 29
Continue Reading Weekly Hospital Real Estate Briefing – Sept. 29