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Tammy Ward Woffenden is a partner in the Corporate Practice Group in the firm's Houston office.

Providers and suppliers participating in the Medicare program should take note of new requirements and compliance considerations related to Medicare enrollment, information updates, changes of ownership, and increased risk for revocation, set to take effect on January 1, 2026. The most consequential changes are found in the CY 2026 Home Health Agency Prospective Payment System (HH PPS) final rule (“Final Rule”), which was published on December 2, 2025.[1] In this Final Rule, Centers for Medicare & Medicaid Services (“CMS”) finalized substantial expansions to its authority to retroactively revoke enrollment for all types of Medicare providers and suppliers, including hospitals, hospices, and home health agencies to physician practice groups and DMEPOS suppliers related to Medicare enrollment and compliance deficiencies. CMS also shortened reporting deadlines and broadened its ability to suspend enrollment during investigations. These changes apply across all Medicare provider and supplier types and significantly tighten compliance expectations. The Final Rule further introduces targeted revisions for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (“DMEPOS”) suppliers, including expansion of the Medicare 36-month rule and increased survey and reaccreditation frequency.Continue Reading Medicare’s New Enrollment, Reporting and Oversight Landscape: What Providers and Suppliers Need to Know for 2026

State oversight of healthcare transactions is continuing to undergo a significant transformation. As tracked in our updated Healthcare Merger Matrix, the number of states implementing or considering expanding antitrust laws targeting proposed deals continues to rise.[1] For instance, Washington and Colorado’s premerger notification laws went into effect on July 27 and August 6, 2025, respectively, and Indiana recently modified its existing transaction notice law to exempt certain practitioner-owned practices.[2] Additionally, New Mexico enacted a permanent version of its temporary transaction notification law with enhanced oversight and enforcement.[3]Continue Reading State Antitrust Enforcement Roundup: Updates to Healthcare Merger Matrix; New Potential Legislation Targeting Private Equity and Other For-Profit Entities in Healthcare