Medicare Expands Pay-for-Performance Demonstration Projects

Foley & Lardner LLP (Foley) represented Carbon Health in negotiating a settlement agreement with the California Attorney General (AG) to resolve alleged corporate practice of medicine (CPOM) violations against Carbon Health, a technology-based primary and urgent care company that recently emerged from Chapter 11 bankruptcy.

On June 22, 2026, 17 states, led by Nebraska, along with the National Association of Wholesaler-Distributors (NAW), sued California regulators and the Circular Action Alliance (CAA) in federal court, seeking to invalidate the state’s landmark packaging law, SB 54 (“SB 54” or “the Act”).  The lawsuit, Nebraska v. Heller, is the first coordinated, multistate attack on the broader “extended producer responsibility” (EPR) model gaining traction for packaging regulation across the United States.  

For health care companies, investors, management services organizations, provider platforms, and boards, the more important message is more specific: the government is now treating fast-growing reimbursement categories as data-driven, enterprise-risk environments.