Persistent workforce shortages continue to define the post-pandemic healthcare landscape. Hospitals, health systems, and long-term care providers report enduring deficits in nursing, primary care, and behavioral health staffing, with projections indicating that these shortfalls are likely to persist through the next decade.[1]Continue Reading Navigating Healthcare Workforce Shortages: Evolving Scope-of-Practice and Staffing Regulations
California’s physician assistant (“PA”) practice landscape is set to undergo significant transformation following the enactment of California Assembly Bill 1501 (AB 1501), which was signed into law by Governor Newsom on October 1, 2025, and will take effect on January 1, 2026. Among its key provisions, AB 1501 extends the authority of the California Department of Consumer Affairs’ Physician Assistant Board (the “Board”) through January 1, 2030, increases the physician-to-PA supervision ratio from 1:4 to 1:8 in all settings, and directs the Board to study scope-of-practice structures—with input from stakeholders—to evaluate potential models from other states that could benefit California. These modernization efforts are designed to enhance healthcare access and better align PA practice with current workforce demands. This article summarizes the key reforms implemented by AB 1501 and offers guidance on how PAs and their practices can prepare for these new requirements.Continue Reading AB 1501 Becomes Law: How It Will Reshape California PA Practice
On Monday, October 6, 2026, Governor Gavin Newsom signed into law SB 351, which codifies restrictions on private equity firms and hedge funds from influencing the clinical decision-making of California physicians and dentists.Continue Reading California Enacts SB 351: New Law Aimed at Limiting Private Equity Influence on Healthcare Businesses
Nearly three years ago, the passage of California Bill AB 890, effective January 1, 2023, set in motion a future pathway for qualified nurse practitioners (“NPs”) to practice independently under a new category of licensure. Specifically, AB 890 delineated two potential pathways for California NPs to practice without standardized procedures in certain settings:[1] as “103 NPs” and “104 NPs” (described below). On January 1, 2026, nurse practitioners licensed in California will be eligible for “104 NP” status for the first time. Here, we explore interim legal developments since AB 890 took effect, and discuss how healthcare organizations can incorporate 103 NPs into their existing workforce and strategically prepare for 104 NPs.Continue Reading Pulse Check: How is Your California Practice Leveraging “103 NPs” – and Preparing for the Arrival of “104 NPs” in 2026?
Congress passed the Corporate Transparency Act (the “CTA”) in 2021 with the aim of enhancing transparency in entity structures and ownership as well as combating terrorism, money laundering, and other forms of corporate misconduct. This sweeping new rule is designed to cast a wide net over entities that, except in the case of taxes, do not regularly report to federal agencies (i.e., non-publicly traded entities), regardless of the degree to which they are already regulated at the state level. This post specifically speaks to medical groups and management services organizations (“MSOs”) that now need to navigate the new CTA requirements and account for their complex contractual relationships (e.g., management services agreements, equity restriction or succession agreements). For additional information on a particular topic, links to helpful resources have been provided in the footnotes.Continue Reading The Corporate Transparency Act: A Reporting Guide for Medical Groups and MSOs
On December 28, 2023, the Office of Inspector General (the “OIG”) issued a favorable Advisory Opinion (No. 23-15) (the “Opinion”) to a consulting vendor (the “Requestor”) that wanted to provide up to $75 in gift cards to physician practices in exchange for referring the Requestor’s practice optimization services (e.g., workflow and performance assessment, data analytics, and certain Medicare eligibility and performance assistance). Among other things, the Requestor: (i) did not itself provide any services that were eligible for reimbursement under any Federal healthcare program to any of its clients, (ii) did not have an ownership or investment interest in any entity that provided items or services paid for by any Federal healthcare program, and (iii) received compensation from the physician practices that did not vary based on whether the physician practices received a greater or lesser reimbursement from Medicare based on the Requestor’s services. The Opinion concluded that this proposed arrangement would not generate prohibited remuneration under Section 1128B(b) of the Social Security Act (the “Act”), also known as the Federal Anti-Kickback Statute (“Anti-Kickback Statute”), and thus OIG would not impose administrative sanctions under Section 1128A(a)(7) (exclusion) or Section 1128(b)(7) (civil monetary penalty) of the Act on the Requestor. As always, the Opinion stipulated that it may only be relied on by the Requestor on the specific facts presented to OIG, and that certain state and federal laws may continue to limit similar arrangements. However, the Opinion indicates that the tight scope of potential marketing options for physician practice vendors could expand a bit for those who are similarly situated to the Requestor.Continue Reading New Marketing Possibilities for Vendors Contracted with Medicare Providers and Suppliers Following OIG’s Favorable Advisory Opinion on Limited Referral Bonuses
Introduction: Defining Interprofessional Consultation
In a January 5, 2023, letter to state health officials, the Centers for Medicare & Medicaid Services (“CMS”) clarified a Medicaid and Children’s Health Insurance Program (“CHIP”) policy on the coverage and payment of interprofessional consultations (the “Guidance”). An interprofessional consultation occurs when the patient’s treating physician requests the opinion and/or advice from a specialist practitioner without the patient making face-to-face contact with the specialist practitioner. The new CMS guidance clarifies that it is permissible for Medicaid and CHIP to provide reimbursement for an interprofessional consultation when the consultation is for the direct benefit of the patient without the patient’s presence.[1]Continue Reading CMS Issues Interprofessional Consultation Guidance
In a recent blog post, we described general registration and application considerations for employers seeking to enroll in California’s new Hospital and Skilled Nursing Facility COVID-19 Retention Payment Program (the “WRP”) on behalf of their employees, including details on eligibility, qualifying periods, and defined legal terms. Readers have asked how to analyze whether physicians and other employees who perform at least some “management” or “supervisory” duties qualify for the WRP, which we address here.Continue Reading Who is a Manager or Supervisor Excluded from California’s Healthcare Worker Retention Payment Program?