Enterprise Risk Management — An Escalated Focus

Medicare payment suspensions result in a cessation of payments for Medicare services until the suspension is resolved, typically several months after the initial action to suspend. Payments withheld will then be released after recoupment of any determined overpayments. The Trump Administration has stated that it will aggressively use its authority (created by the 2010 Affordable Care Act) to suspend payments based upon a credible allegation of fraud. Below we set forth the context for such suspensions, as well as the key parameters for such actions. 

On April 18, 2026, President Donald Trump signed an executive order titled Accelerating Medical Treatments for Serious Mental Illness, directing federal agencies to expedite the research, review, and approval of psychedelic drugs as potential treatments for serious mental health conditions. The Order represents a significant federal policy shift aimed at addressing what the Trump Administration describes as a crisis of serious mental illness in America, with particular emphasis on patients whose conditions have not responded to standard therapies.

According to the PAGA reform statute, employers with at least 100 employees can seek an Early Evaluation Conference within the time required to respond to the lawsuit to allow a neutral evaluator to decide a wide range of issues,