No contract, no problem—at least for now. An Illinois district court (the “Court”) opened the door for hospitals to recover underpaid claims from insurers—holding that a quantum meruit claim may proceed even absent any contract. Lucile Salter Packard Children’s Hosp. v. Health Care Servs. Corp., 2026 WL 278804, No. 25-cv-04533, at *1 (N.D. Ill. Feb. 3, 2026).
Background
Lucile Salter Packard Children’s Hospital (the “Hospital”) sued Health Care Services Corp. (“HCSC”) and related defendants (collectively, “Defendants”) for breach
Continue Reading Illinois Court Allows Hospital’s Quantum Meruit Claim Against Insurer Despite No Contract
Latest from Hall, Render, Killian, Heath & Lyman, P.C. Blog - Page 5
Indiana Court of Appeals Affirms Finding of Grave Disability Despite Initial Admission for Foot Pain
The Indiana Court of Appeals (the “Court”) affirmed a trial court’s determination that a patient was gravely disabled—even though he initially sought care for a physical ailment. The Court held that the patient’s refusal of necessary treatment, combined with his lack of insight into both his medical and psychiatric conditions, satisfied the clear-and-convincing-evidence standard. In re Commitment of G.N., 2025 WL 3633080, No. 25A-MH-1576, at *1 (Ind. Ct. App. Dec. 15, 2025) (unpublished).
Background
In May 2025, G.N. presented
Continue Reading Indiana Court of Appeals Affirms Finding of Grave Disability Despite Initial Admission for Foot Pain
Weekly Hospital Real Estate Briefing: Understanding the Hub and Spoke Model
For years, we’ve heard that outpatient services and home care are the future of health care in the U.S. To a certain extent, that’s true. We’ve seen tremendous growth in outpatient care across the country. Procedures that were once provided in inpatient settings are now provided in ambulatory surgery centers and physician offices. Payers, providers and patients are all pushing for care that can be provided at a lower cost, in a more convenient setting and in a manner
Continue Reading Weekly Hospital Real Estate Briefing: Understanding the Hub and Spoke Model
Indiana Medicaid’s ABA Therapy Overhaul: What Changed on April 1, 2026
Indiana Medicaid implemented significant updates for applied behavior analysis (“ABA”) therapy—one of the most widely used interventions for children with autism spectrum disorder—effective April 1, 2026. The reforms include phased cuts to reimbursement for ABA therapy, updates to member eligibility and revisions to provider qualifications.
The Indiana Health Coverage Programs (“IHCP”) began covering ABA therapy in 2016. Indiana’s expenditures on ABA therapy skyrocketed since coverage began and culminated in increased scrutiny following a Wall Street Journal investigation. Governor Mike
Continue Reading Indiana Medicaid’s ABA Therapy Overhaul: What Changed on April 1, 2026
The Secretary of HHS Must Consult with the States Before Issuing Regulations Changing the Treatment of IGTs
Our previous article, In Defense of IGTs from Governmental Health Care Providers, noted that the Secretary of the Department of Health and Human Services (“HHS”) is required to “consult with the States” before issuing any regulations changing the treatment of intergovernmental transfers (“IGTs”). We received requests for further information about this requirement following the publication of that article, and the requirement gained additional attention following the Secretary’s February 27, 2026, request for information (“RFI”) seeking stakeholder feedback on
Continue Reading The Secretary of HHS Must Consult with the States Before Issuing Regulations Changing the Treatment of IGTs
Weekly Hospital Real Estate Briefing: VA Approves $672M in New Hospital Projects | Rural Funding Bill Introduced | Centurion Closes RI Hospital Deal
FTC Announces Formation of Healthcare Task Force
On March 20, 2026, Federal Trade Commission (“FTC”) Chairman Andrew Ferguson announced the formation of an internal Healthcare Task Force (the “Task Force”) and, in a memorandum issued the same day, directed the FTC’s Bureaus of Competition, Consumer Protection, and Economics, along with the Office of Policy Planning and the Office of Technology, to form the Task Force with the intention of coordinating the FTC’s existing health care enforcement and advocacy efforts across the agency.
What the Task Force
Continue Reading FTC Announces Formation of Healthcare Task Force
HHS Finalizes HIPAA Standards for Health Care Claims Attachments and Electronic Signatures and Signals More Regulatory Updates in 2026
On March 24, 2026, the U.S. Department of Health and Human Services (“HHS”), through the Centers for Medicare & Medicaid Services (“CMS”), published a long‑anticipated final rule adopting national Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) standards for health care claims attachments transactions and electronic signatures (the “Final Rule”). The Final Rule is intended to modernize HIPAA transactions by establishing standards for the electronic exchange of clinical documentation used to support health care claims and related inquiries
Continue Reading HHS Finalizes HIPAA Standards for Health Care Claims Attachments and Electronic Signatures and Signals More Regulatory Updates in 2026
Ninth Circuit Permits 340B-Based FCA Claims to Proceed Despite Lack of Private Right of Action
In a significant decision with implications for 340B enforcement and False Claims Act (“FCA”) whistleblower litigation, the United States Court of Appeals for the Ninth Circuit (the “Court”) held on March 17, 2026, that a health system (the “System”) may proceed with its qui tam action alleging that pharmaceutical manufacturers engaged in fraudulent price-inflation schemes under the 340B Drug Pricing Program (“340B”), in violation of the FCA. United States ex rel. Adventist Health System of West v. AbbVie, et
Continue Reading Ninth Circuit Permits 340B-Based FCA Claims to Proceed Despite Lack of Private Right of Action
Fifth Circuit Denies FTC Stay: HSR Filings Revert to Old Form Effective Immediately
On March 19, 2026, the U.S. Court of Appeals for the Fifth Circuit denied the Federal Trade Commission’s (“FTC”) motion for a stay pending appeal of the U.S. District Court for the Eastern District of Texas’s (the “District Court”) decision vacating the FTC’s 2024 Final Rule (the “2024 Rule”) revising the Hart‑Scott‑Rodino (“HSR”) premerger notification requirements, including the HSR premerger notification form and instructions. As a result, the District Court’s judgment is effective immediately.
Background
As discussed in our
Continue Reading Fifth Circuit Denies FTC Stay: HSR Filings Revert to Old Form Effective Immediately
Conducting Effective Peer Review Investigations
Peer review investigations are a cornerstone of medical staff oversight. They protect patient safety, uphold professional standards and ensure compliance with federal law, state law and accreditation requirements. When concerns arise about a practitioner’s clinical competence or professional conduct, the process must be deliberate, fair and well-documented. Below are key considerations for conducting an effective investigation.
Key Points
Corrective Action vs. Routine Review
Corrective action is not routine review—it is a formal process triggered by concerns about clinical performance
Continue Reading Conducting Effective Peer Review Investigations
Weekly Hospital Real Estate Briefing: Sale-Leaseback Volume Rebounds | CON Updates in MS and TN | Hall Render Hosting ASC Webinar
Tenth Circuit Affirms OSHA Authority to Cite Health Care Employers for Workplace Violence Incidents Under the General Duty Clause
The Tenth Circuit recently issued two companion decisions confirming the Occupational Safety and Health Administration’s (“OSHA”) authority to cite employers for workplace violence hazards under the General Duty Clause of the Occupational Safety and Health Act, 29 U.S.C. § 654(a)(1) (“General Duty Clause”). In both cases, the Tenth Circuit upheld OSHA’s enforcement actions and the citations issued in connection with workplace violence incidents in a psychiatric hospital.
Case Background
Both cases stem from OSHA’s investigation into a psychiatric hospital
Continue Reading Tenth Circuit Affirms OSHA Authority to Cite Health Care Employers for Workplace Violence Incidents Under the General Duty Clause
Health Care Privacy Law Takeaways for a Compliant 2026: Pay Attention to Patient Concerns
Once again, 2025 was a busy year for health care data privacy. Ensuring up-to-date and compliant data privacy and security programs and being able to assess, understand and adapt to the risk of evolving technologies will remain critically important in 2026. We continue to await updated regulations under both the Health Insurance Portability and Accountability Act (“HIPAA”) of 1996 and the Information Blocking Rule, both of which are subject to proposed rules likely to be finalized this year, which
Continue Reading Health Care Privacy Law Takeaways for a Compliant 2026: Pay Attention to Patient Concerns
Weekly Hospital Real Estate Briefing: Five Takeaways from Our Hospital Campus Development Trends Webinar
On March 12, we hosted a webinar titled Hospital Campus Development: Current Deals, Trends and Insights Learned Along the Way. To watch a video replay of the webinar and to get copies of our slides, click here.
Here are our top five takeaways from the webinar:
CMS Issues Guidance Clarifying OPO and Donor Hospital Responsibilities During the Organ Donation Process
On March 11, 2026, the Centers for Medicare & Medicaid Services (“CMS”) issued a Quality, Safety & Oversight (“QSO”) memorandum and related updates to the State Operations Manual (“SOM”) interpretive guidance clarifying and reinforcing existing responsibilities of organ procurement organizations (“OPOs”) and donor hospitals throughout the organ donation process. While the memorandum largely reiterates existing regulatory requirements, CMS also clarifies expectations regarding regulatory compliance, oversight of OPO activities and appropriate collaboration among OPOs and donor hospitals. OPOs and donor
Continue Reading CMS Issues Guidance Clarifying OPO and Donor Hospital Responsibilities During the Organ Donation Process