News & Analysis as of

Consolidated Appropriations Act (CAA)

Baker Donelson

New Medicare Requirements for Off-Campus Provider-Based Departments: Separate NPIs and Attestations Required by January 1, 2028

Baker Donelson on

Introduction and Summary - As part of the Consolidated Appropriations Act, Congress established new identification and attestation requirements for off-campus outpatient departments of acute care hospitals. Although Medicare...more

McGuireWoods LLP

Understanding Congress’ Latest Extension of Medicare Telehealth Flexibilities

McGuireWoods LLP on

On Feb. 3, 2026, President Donald Trump signed into law the FY 2026 appropriations bill, the Consolidated Appropriations Act of 2026, which extends pandemic-era Medicare telehealth flexibilities through Dec. 31, 2027....more

Warner Norcross + Judd

PBM Reform is Here: What CAA 2026 Means for Employer Health Plans

Warner Norcross + Judd on

On Feb. 3, 2026, President Donald Trump signed into law the Consolidated Appropriations Act, 2026 (CAA 2026), a sweeping piece of legislation including provisions that will substantially impact employer-sponsored health...more

Foley & Lardner LLP

PBM Reform Cheat Sheet: Chart Comparing the Recent Rules for Group Plans

Foley & Lardner LLP on

Within a one-week period, there were two actions at the federal level to increase pharmacy benefits manager (PBM) transparency. The Consolidated Appropriations Act of 2026 (CAA 2026) and Department of Labor (DOL) proposed...more

Hogan Lovells

Latest congressional spending package includes important updates for orphan disease and pediatric drug development

Hogan Lovells on

On February 3, 2026, President Trump signed into law the Mikaela Naylon Give Kids A Chance Act as part of the Consolidated Appropriations Act (CAA) of 2026. The CAA codifies FDA's interpretation of the scope of orphan drug...more

Baker Donelson

Medicare Telehealth Waivers Extended for Several More Years

Baker Donelson on

President Trump has signed the Consolidated Appropriations Act, 2026 (CAA, 2026), extending Medicare telehealth flexibilities through December 31, 2027, and Acute Hospital Care at Home authorities through September 30, 2030....more

Groom Law Group, Chartered

Drug Pricing and Plan Contracting Practices Under Scrutiny: PBM and TPA Reforms in the Consolidated Appropriations Act, 2026

On February 3, 2026, Congress passed and the President signed the Consolidated Appropriations Act, 2026 (“CAA 26”), a legislative package that funds several federal agencies, including the Departments of Labor and Health and...more

Pullman & Comley - Connecticut Health Law

Medicare Telehealth Flexibilities Extended Through December 2027

As a follow-up to our post earlier this week, President Trump has signed into law the Consolidated Appropriations Act, 2026 (CAA). The law extends key COVID-19 era Medicare telehealth flexibilities through December 31, 2027...more

Polsinelli

Mandatory Provider-Based Attestations Make a Comeback

Polsinelli on

After a nearly 24-year hiatus from the mandatory provider-based attestation requirement, the Consolidated Appropriations Act of 2026 (Act, signed into law on Feb. 3, 2026), mandates (again) that hospitals file attestations of...more

Baker Donelson

Deadline to Apply for Final Round of Medicare-Funded GME Residency Positions

Baker Donelson on

Teaching hospitals training over their graduate medical education (GME) caps have limited opportunities to receive additional funding from Medicare. Therefore, it is important to note the upcoming March 31, 2026, deadline to...more

Bass, Berry & Sims PLC

A Band-Aid on PAMA: Appropriation Bill Delays Cuts & Reporting Period; Updates Data

On February 3, 2026, President Trump signed into law the Consolidated Appropriations Act, 2026 (H.R.7148), an appropriations act that provides funding for various agencies including the Department of Health and Human...more

Bass, Berry & Sims PLC

Congress Enacts New Attestation and Identifier Requirements for Off-Campus Hospital Outpatient Departments

The Consolidated Appropriations Act, 2026, which was signed into law on February 3, 2026, includes a significant new requirement affecting off-campus hospital outpatient departments....more

Akin Gump Strauss Hauer & Feld LLP

PBM Reform Picks Up Pace with Enactment of Consolidated Appropriations Act, PBM Fee Disclosure Proposed Rule

Pharmacy benefit manager (PBM) reform has been an active and evolving area for policymakers in Washington, D.C. for many years but reform efforts have noticeably picked up pace in 2026. Recent actions by Congress and the...more

McDermott Will & Schulte

Hospitals: Prepare now for mandatory provider-based attestation process

All hospitals that are paid under the Medicare Outpatient Prospective Payment System and operate off-campus outpatient departments should prepare for submission of mandatory provider-based attestations (PBAs), even if they...more

Roetzel & Andress

Medicare Telehealth Expansion Continues Under New Federal Extension

Roetzel & Andress on

Providers that rely on telehealth for Medicare patients can continue to do so as a result of an extension of the Medicare telehealth rules that were originally implemented during the COVID-19 Public Health Emergency...more

Pullman & Comley - Connecticut Health Law

Medicare Telehealth Rules After January 30, 2026: What Practitioners Need to Know Now

During the COVID-19 public health emergency, the federal government eased some of the restrictions placed on the provision of health care services through telehealth for Medicare beneficiaries. ...more

McDermott+

Healthcare Preview for the Week of: January 26, 2026

McDermott+ on

Last week, the House passed the 2026 Consolidated Appropriations Act, which includes the fiscal year 2026 appropriations bill for Labor-Health and Human Services (HHS) and a host of key healthcare extenders....more

McDermott+

McDermott+ Check-Up: January 23, 2026

McDermott+ on

Congressional leaders release FY 2026 Labor-HHS minibus and health package. On January 20, 2026, congressional appropriators released the 2026 Consolidated Appropriations Act, working to ensure that government funding does...more

Shumaker, Loop & Kendrick, LLP

Client Alert: U.S. House Releases Consolidated Appropriations Act, 2026 – Key Health Care Funding and Policy Provisions

As Congress continues negotiations over federal funding priorities, health care providers, research institutions, and other industry stakeholders are closely monitoring developments that could affect reimbursement, compliance...more

McDermott+

Healthcare Preview for the Week of: January 20, 2026

McDermott+ on

Early on January 20, 2026, the House Appropriations Committee released the 2026 Consolidated Appropriations Act, which includes the last of the 12 fiscal year (FY) 2026 appropriations bills: Labor-Health and Human Services...more

Jackson Lewis P.C.

The 5th Cir. Will Reconsider Whether the PWFA Was Constitutionally Enacted

Jackson Lewis P.C. on

Late yesterday, the 5th Circuit Court of Appeals vacated the split panel opinion from August allowing enforcement of the Pregnant Workers Fairness Act (PWFA) against the state of Texas. The issue is whether the U.S....more

Haynes Boone

Reminder—Gag Clause Attestation Due December 31st

Haynes Boone on

Group health plan sponsors must file the annual gag clause attestation required by the Consolidated Appropriations Act of 2021 by December 31st on the CMS website (here). Plans must attest that agreements with third party...more

Ballard Spahr LLP

Courts Split on Enforcement of No Surprises Rules

Ballard Spahr LLP on

The Fifth Circuit and the Federal District Court of Connecticut have issued conflicting decisions on whether service providers may sue to enforce arbitration awards under the No Surprises Rules in the Consolidated...more

Husch Blackwell LLP

MHPAEA July 2025 Update: What Employers and Plans Need to Know about Federal Non-Enforcement

Husch Blackwell LLP on

The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) was enacted to ensure that group health plans and health insurance issuers offering mental health and substance use disorder (MH/SUD) benefits do not impose...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Gag Clause Prohibitions

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses prohibitive gag clauses under the Consolidated Appropriations Act (CAA). While intended to promote transparency, not all gag clauses are...more

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