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HHS Clarifies NPDB Reporting Obligations

Client Alert | 1 min read | 09.24.03

Some health care entities have expressed concern that the National Practitioner Data Bank regulations require health care entities to report adverse actions taken against practitioners to both the NPDB and the applicable State Board of Medical Examiners, while the NPDB Guidebook directs health care entities to report directly to the NPDB first, and then subsequently to send to the State Board the Report Verification Document that the NPDB sends to the plan confirming receipt of the adverse action report in satisfaction of the plan's Board reporting obligation. We requested confirmation of health care entity obligations from the NPDB, and received the attached letter from HRSA Deputy Administrator Cynthia Grubbs in response. The letter confirms the process set forth in the Guidebook, and should provide additional comfort to health care entities who may have been unsure of their obligations.

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Client Alert | 4 min read | 03.05.26

DOL’s Proposed Independent Contractor Rule Reverts to Prioritize Two Core Factors – Likely Limiting Misclassification Claims by Contractors

The U.S. Department of Labor (DOL) has proposed another revision to independent contractor regulations, one that would provide for more leeway in classifying workers as contractors. DOL’s proposed rule, published on February 26, 2026, would rescind the Biden DOL’s March 2024 independent contractor regulation and reinstate a framework substantially tracking the prior Trump rule of January 2021. The proposed rule would also apply the narrower analysis to worker classifications under the Family and Medical Leave Act (FMLA) and the Migrant and Seasonal Agricultural Worker Protection Act (MSPA). The comment period closes in late April 2026; until then, the 2024 rule remains in effect for purposes of private litigation....