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4.14.26
Firm Advises Getlabs on Acquisition by Function
On April 8, 2026, Function Health announced it has acquired Getlabs, a leading mobile healthcare platform that brings licensed specialists directly to one's location. The acquisition allows for the continuation of Getlab’s nationwide network of providers, health systems, and partners, while advancing Function's broader commitment to making healthcare more accessible by building experiences around member needs. Wilson Sonsini Goodrich & Rosati advised Getlabs on the transaction.
Alerts
12.19.25
Navigating CMS’s ACCESS Model and FDA’s TEMPO Pilot: Opportunities for Digital Health Companies
Since the publication of this Alert, CMS has officially released the Request for Applications (RFA), which provides clarifications and significantly more detail on eligibility criteria, application timelines, requirements for each ACCESS Participant’s Medical Director, eligibility for inclusion in the Tools Directory, and the model’s financial structure. Interested organizations should carefully review the RFA for specific requirements that were not available at the time this Alert was published and may contact Wilson Sonsini’s Digital Health practice with any questions.
Alerts
12.16.25
Trump Administration Issues Executive Order on National AI Policy and Deregulation
On December 11, 2025, the White House issued an Executive Order (EO), “Ensuring a National Policy Framework for Artificial Intelligence,” that establishes a new federal policy on artificial intelligence (AI). The EO states that it is “the policy of the United States to sustain and enhance the United States’ global AI dominance through a minimally burdensome national policy framework for AI.” The EO asserts that leadership in AI is critical to U.S. national and economic security and dominance and that “AI companies must be free to innovate without cumbersome regulation.” To accomplish this, the EO seeks to challenge “onerous” state AI laws through various federal actions.
Client Advisories
8.19.25
Offering Equity to Physicians in an MSO/PC Structure: Key Fraud and Abuse Compliance Considerations
Offering equity in MSOs to physicians can be permissible but must be structured to comply with both federal and state laws. Failure to comply with applicable fraud and abuse laws may result in civil and/or criminal penalties, repayment obligations, and exclusion from federal healthcare programs.
Alerts
8.01.25
CMS Announces Creation of Health Tech Ecosystem for Improving Access to Patient Data
During a “Make Health Tech Great Again” event on July 30, 2025 at the White House, the Centers for Medicare & Medicaid Services (CMS) announced its intent to create a digital health ecosystem, in partnership with private industry, to improve patient outcomes, reduce provider burden, and drive value by making it easier to access and share patient data.
Alerts
6.13.25
Oregon Enacts Nation’s Most Restrictive CPOM Law
Since publication, the statute referenced in this alert has been amended by HB 3410. Readers should consult this updated law or contact our team for information on updates to the following requirements.
Alerts
5.05.25
Telehealth Companies Sued for Selling Compounded GLP-1 Drugs and Violations of Corporate Practice of Medicine Laws
Branded drug manufacturers, including Eli Lilly and Company (Eli Lilly), have been pursuing various legal actions against compounding pharmacies and telehealth companies that provide compounded diabetes and weight-loss drugs, escalating the legal battle after the FDA removed the drugs from the shortage list. Legal claims raised by the branded drug manufacturers under federal laws have included the Lanham Act and the Federal Food, Drug, and Cosmetic Act (FDCA). In the latest series of lawsuits brought on April 23, 2025, Eli Lilly asserted that the telehealth companies violated the Lanham Act and California laws by engaging in unfair, deceptive, false, and misleading advertising and practices over the safety, effectiveness, and quality of the compounded drugs. Additionally, for the first time in this line of cases, Eli Lilly also asserted that the telehealth companies violated California’s corporate practice of medicine (CPOM) laws.
Client Advisories
3.27.25
The Corporate Practice of Medicine: Essential Guidance for Digital Health Companies and Investors
As digital health companies blossom from ideas into reality, navigating state regulations on the corporate practice of medicine (CPOM) is typically one of the first and most crucial legal hurdles to clear if the digital health company seeks to deliver professional healthcare services. Many states have strict rules about 1) what type of entities can perform medical services and 2) who can have an ownership interest in entities that provide those medical services. In many states, only a professional medical entity, and not a general corporation, can provide medical services. In addition, many states also limit ownership of professional medical entities to people with certain medical licenses. These ownership rules vary by state, though all states permit a licensed physician to be the sole owner of a medical group. For nonmedical personnel, including founders, venture capital firms, private equity, and other investors, this means that they generally cannot invest in entities that provide medical services.