GNYHA recently hosted a live, full-day program for in-house hospital counsel that offered continuing legal education (CLE) credits for New York State-admitted attorneys. GNYHA became an accredited CLE provider in 2024 and provides CLE credits for regular member educational programming as appropriate.
GNYHA Legal, Regulatory, and Professional Affairs staff developed and presented all content. Topics included an analysis of the key executive orders (EOs) and executive actions—and related legal challenges—affecting GNYHA member hospitals and health systems, with a focus on gender-affirming care for minors and diversity, equity, and inclusion programs.
Staff also discussed the evolution of the Federal Hospital Price Transparency Rule, which went into effect in 2021 and requires hospitals to provide clear and accessible pricing information online. The rule, which is overseen and enforced by the Centers for Medicare & Medicaid Services, has placed additional pricing pressure on hospitals.
Lori Lahn discussed the evolution of the Federal Price Transparency Rule.
The meeting also covered ongoing State budget negotiations and GNYHA’s comments on Office of Medicaid Inspector General provider compliance program requirements, which seek to reduce the review timeframe to every three years instead of annually. Another key topic was New York State’s Hospital Financial Assistance Law and how it has been amended since its enactment. Among the revisions, the law now applies to all New York State Department of Health-licensed hospitals (Article 28 hospitals) and eligibility has been expanded to include those earning less than 400% of the Federal Poverty Level.
Staff discussed the role of artificial intelligence (AI) in hospital operations, including takeaways from GNYHA’s AI Advisory Group, which is advocating for the need to balance regulation with innovation and establish governance and risk management frameworks. Additionally, staff highlighted GNYHA’s AI Activity Tracker, which captures AI-related legislative and regulatory activities and major policy developments. This GNYHA resource—which is organized by national, New York State, and New York City efforts—will be updated quarterly and is available to all members.
Staff also shared an update on the Statewide Health Information Network of New York, including the statewide consent to access form and amendments to 10 NYCRR Part 300, which establishes a central data repository to which hospitals would be required to submit information. Additionally, staff discussed the HIPAA rule on protecting reproductive health information, including its prohibitions on using or disclosing protected health information, and New York State oversight of behavioral health, including the State’s billion-dollar investment to expand access and reduce wait times across the care continuum.
Puja Khare shared updates on the Statewide Health Information Network of New York (SHIN-NY).
Finally, staff highlighted GNYHA legal resources for members, including an updated Record Retention Grid, HIPAA Guide, and Immigration Enforcement Toolkit.