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Madeline Cunnion is an associate in the Governmental Practice in the firm's Washington, D.C. office and a member of the Healthcare Industry Team.

On December 31, 2025, the Drug Enforcement Administration (“DEA”) and the Department of Health and Human Services (“HHS”) jointly issued a Fourth Temporary Rule again extending the telemedicine flexibilities of the Ryan Haight Act (the “RHA”), now through December 31, 2026.Continue Reading 2026 Extension of Telemedicine Prescribing Flexibilities: Impacts on Patients and Providers

The Centers for Medicare & Medicare Services’ (“CMS”) Innovation Center will begin accepting applications on January 12 for the recently announced Advancing Chronic Care with Effective, Scalable Solutions (“ACCESS”) Model—a nationwide voluntary alternative payment model for Medicare Part B commencing July 5, 2026 that will run for 10 years and focus on chronic conditions affecting over two-thirds of Medicare beneficiaries such as diabetes, high blood pressure, and depression.[1]­ Health care organizations, such as physician groups, must be enrolled in Medicare Part B to be eligible to participate as an ACCESS “Participant” and must take responsibility for delivering integrated, coordinated services—in person, virtually, asynchronously, or through other technology-enabled modalities—to Medicare patients to manage those patients’ chronic conditions for a twelve-month period. Participants must designate a Medicare-enrolled Medical Director to oversee care quality and compliance. The Model will initially encompass four non-mutually-exclusive clinical tracks corresponding to common chronic conditions[2]:Continue Reading Application Window Opens Soon for CMS ACCESS Model Expanding Technology-Supported Care Options for Traditional Medicare

In early August, Illinois enacted the Wellness and Oversight for Psychological Resources Act (HB 1806, or the “Act”), making it the first state to pass a law regulating the use of AI[1] in the delivery of therapy and psychotherapy services. The Act, which took immediate effect, imposes guardrails on the use of AI to provide decision-making therapeutic support services, but permits the use of AI for administrative and supplementary tasks, subject to certain consent requirements. This blog post summarizes the Act and addresses its potential implications for the use of agentic AI by Illinois therapy providers.Continue Reading Illinois Becomes the First State to Regulate the Use of AI Mental Health Therapy Services