Scott Driggs

Building on our April alert regarding Colorado’s three-front AI healthcare landscape, the legislature has finalized all three tracks. The compliance picture has rapidly shifted, bringing unexpected framework changes that demand immediate attention. Front One: SB 24-205 Is Gone — Replaced by SB 26-189 The original Colorado AI Act never took effect.

On April 23, 2026, the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) updated its FAQs on General Questions Regarding Certain Fraud and Abuse Authorities with two notable additions: a revised FAQ No. 4 addressing the interplay between the physician self-referral law (Stark Law) and the federal Anti-Kickback Statute (AKS), and a new FAQ No. 17 clarifying the role of fair market value (FMV) in AKS compliance.

Re: State of Minnesota v. Oz, Case No. 26-cv-1701 (D. Minn. Apr. 6, 2026) On April 6, 2026, the U.S. District Court for the District of Minnesota denied the State of Minnesota’s motion for a preliminary injunction seeking to block the Centers for Medicare & Medicaid Services (“CMS”) from deferring over $259 million in federal Medicaid matching funds.