Little Health Law Blog

Does the No Surprises Act Apply to Your Practice? Understanding the Good Faith Estimate Requirement for Cash-Only and Self-Pay Providers

May 6, 2026 | Little Health Law

Our healthcare and business law firm advises many medical practices, including telemedicine and cash-only practices, on regulatory compliance. A question we frequently receive is whether the No Surprises Act applies to a practice that does not participate in any insurance network. The answer is not always straightforward—the No Surprises Act has several distinct components, and whether a particular requirement applies depends on what type of entity or provider is involved. This post explains the structure of the Act, discusses the Good Faith Estimate (“GFE”) requirement and which providers it reaches, and outlines practical compliance steps. If you would like to discuss No Surprises Act compliance for your practice or would like to discuss this blog post, you may contact our healthcare and business law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

(1) The No Surprises Act Has Multiple Components

The No Surprises Act was enacted as part of the Consolidated Appropriations Act of 2021 and created a suite of consumer protections against unexpected medical bills. It is important to understand that not all of those protections apply to the same entities. Some provisions—particularly those addressing surprise billing for emergency services and certain non-emergency services—are tied specifically to “health care facilities,” a defined term that encompasses hospitals, hospital outpatient departments, critical access hospitals, and ambulatory surgical centers. Those facility-specific provisions are primarily designed for the insured-patient context, where a patient receives care at an in-network facility but is Continue reading ›

Who Can Draw Blood?

April 30, 2026 | Little Health Law

Our healthcare law firm works with many providers and healthcare practices to assist them in complying with federal, state, and local laws. This blog post discuses which licensed professionals can draw blood in Georgia depending on the particular circumstance and the professional’s particular license. If you are planning to draw blood as part of your scope of practice, respond to a licensing dispute about drawing blood, or would like to discuss this blog post, you may contact our healthcare law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

Georgia law and regulations do not have clear rules on who can or cannot draw blood. Regarding blood donation centers, for example, phlebotomists must have the Continue reading ›

Who Can Administer Botox in South Carolina?

April 23, 2026 | Little Health Law

Our healthcare law firm works with many providers and healthcare practices to assist them in complying with federal, state, and local laws. Our med spa clients in South Carolina ask what services they can legally provide at their med spa, especially Botox. This blog post discuses who can administer Botox in South Carolina. If you are planning to start a med spa in South Carolina, administer Botox in your practice, or would like to discuss this blog post, you may contact our healthcare law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

Who Can Administer Botox Depends on Whether Botox Is Being Administered for Cosmetic or Non-Cosmetic Purposes.

The South Carolina State Boards of Dentistry, Medical Examiners, and Nursing issued a joint advisory opinion about administering neuromodulators, including Botox, for cosmetic and non-cosmetic purposes. The opinion discusses certain requirements to administer Botox. A practitioner must Continue reading ›

Is the Service You Offer a Medicare-Covered Service?

April 16, 2026 | Little Health Law

Our healthcare and business law firm advises many physicians and medical practices on Medicare compliance, including one of the most foundational questions a Medicare-participating provider must answer before offering a new service: is this a covered service? The answer has significant legal and financial consequences. This post walks through a framework for analyzing whether a service is covered under Medicare, why that distinction matters, and what options a provider has when a service may or may not be covered. If you would like to discuss Medicare compliance for your practice or would like to discuss this blog post, you may contact our healthcare and business law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

(1) Why the Covered vs. Non-Covered Distinction Matters

As a Medicare-participating provider, you have agreed—through your provider agreement—to accept Medicare’s approved payment amount as payment in full for covered services. That means if a service is covered by Medicare, you generally cannot bill the patient a separate or higher fee for that same service. Doing so can result in severe penalties, including civil monetary penalties and exclusion from the Medicare program.

On the other hand, if a service is never a covered service, you are not bound by Medicare’s billing rates, are not required to submit a claim to Medicare, and can Continue reading ›

FDA Issues Warning Letters to Companies Marketing Compounded GLP-1s

April 14, 2026 | Little Health Law

Our healthcare and business law firm advises many medical practices, telehealth companies, and providers on compliantly offering weight management services, including GLP-1 medications. On February 20, 2026, the Food and Drug Administration (“FDA”) issued warning letters to numerous companies offering compounded GLP-1 medications—specifically compounded semaglutide and tirzepatide. This post summarizes the FDA’s warning letter actions and outlines the top concerns the FDA has identified regarding how companies are marketing and labeling compounded GLP-1 products. If you would like to discuss GLP-1 compliance matters or would like to discuss this blog post, you may contact our healthcare and business law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

(1) Background: FDA Warning Letters on Compounded GLP-1s

GLP-1 medications such as semaglutide (the active ingredient in Ozempic® and Wegovy®) and tirzepatide (the active ingredient in Mounjaro® and Zepbound®) have become among the most prescribed drugs in the United States. Given high demand and prior drug shortages, a large market for compounded versions of these drugs developed. As the FDA resolved shortage designations for these drugs, it began more actively scrutinizing how compounders and telehealth platforms were marketing their compounded GLP-1 products.

On February 20, 2026, the FDA’s Center for Drug Evaluation and Research (CDER) issued a wave of warning letters to companies offering compounded semaglutide and tirzepatide products. Three of those letters—sent to Continue reading ›

If You Are Renting Space with Another Practice (Part 2)

April 7, 2026 | Little Health Law

This blog post follows our previous blog post about HIPAA compliance concerns with subleasing or sharing space with another practice. Subleasing or renting rooms carries other legal risks, besides HIPAA concerns, that this blog post covers. If you are starting a practice or med spa and plan to sublease or rent space from another practice, or would like to discuss this blog post, you may contact our healthcare law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

Providers Who Accept Medicare and Medicaid Also Need to Comply with Federal Fraud and Abuse Requirements to Ensure the Compensation for the Shared Rental Space Reflects the Fair Market Value of the Rental Space.

Federal regulators have flagged rental arrangements where entities share space with physicians for over 25 years. In 2000, the Department of Health and Human Services’ Office of Inspector General (HHS-OIG) issued a Special Fraud Alert highlighting concerns that rental payments may appear to be disguised kickbacks to induce referrals. Federal fraud and abuse laws, such as Continue reading ›

Are You Prepared for the Changes to HIPAA’s Notice of Privacy Practices Requirement?

April 4, 2026 | Little Health Law

If your practice has not yet updated its HIPAA Notice of Privacy Practices (NPP), action is overdue. Effective February 16, 2026, all HIPAA-covered health care providers are required to revise their NPP to reflect new federal rules governing the confidentiality of substance use disorder (SUD) treatment records under 42 C.F.R. Part 2 (“Part 2”). These changes stem from the CARES Act and a 2024 HHS final rule that aligned Part 2 more closely with HIPAA while preserving heightened protections for SUD patient records.

Importantly, this obligation is not limited to practices that specialize in SUD treatment. The updated NPP requirements apply to any HIPAA-covered health care provider that creates or maintains Part 2 records — including providers who receive SUD treatment records from other sources in the course of treating a patient, such as through care coordination, referrals, or integrated care arrangements. In other words, if your practice could receive records identifying a patient as having received SUD diagnosis, treatment, or a referral for treatment at a federally assisted program, your NPP must address Part 2’s requirements.

The changes require NPPs to include the following:

South Carolina Bill Regulating Non-Competes in Physician Employment Contracts

April 3, 2026 | Little Health Law

Our healthcare law firm works with many providers and healthcare practices to assist them in complying with federal, state, and local laws. Several of our clients in South Carolina have concerns about their non-compete in their employment agreement. South Carolina has proposed a bill to regulate non-competes in employment agreements for physicians. The bill does not apply to employment agreements of mid-level providers, including physician assistants and nurse practitioners, or other licensed healthcare personnel, such as registered nurses.

This blog post discusses the bill in the South Carolina General Assembly that proposes to eliminate non-competes and highlights other common provisions of concern found in physician employment agreements. As of March 30, 2026, the bill has passed the South Carolina House and is currently in the South Carolina Senate. If you are a South Carolina physician who has concerns about their employment agreement, is planning to negotiate their employment agreement, is about to enter a new employment agreement for a new job, or would like to discuss this blog post, you may contact our healthcare law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

House Bill 4767 (H. 4767) first declares that non-competes in physician contracts are against South Carolina public policy, and certain provisions in physician contracts are void and unenforceable. These provisions include non-competes, restrictions on physicians continuing to Continue reading ›

Georgia Bill Regulating Ketamine Clinics

March 31, 2026 | Little Health Law

Our healthcare law firm works with many providers and healthcare practices to assist them in complying with federal, state, and local laws. Several of our clients have asked if they can administer ketamine for off-label use, especially for treatment-resistant depression. Ketamine has started being administered in psychiatric practices and ketamine clinics, and states are starting to respond to the proliferation of these ketamine clinics. This blog post discusses a bill in the Georgia General Assembly that proposes to regulate ketamine clinics. As of March 30, 2026, the bill has passed both the Georgia House and Senate but has not yet become law. If you are planning to administer ketamine in your practice, would like to set up a ketamine clinic, or would like to discuss this blog post, you may contact our healthcare law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

House Bill 717 (HB 717) proposes to regulate facilities that administer “psychedelic-assisted treatment and therapy,” which includes ketamine that is administered intravenously. “Psychedelic-assisted treatment and therapy” is defined as any treatment or therapy using psychedelic, dissociative, or other related substances that can produce hallucinations or other similar feelings. This bill also covers other treatments similar to ketamine, including Spravato®. The Georgia Medical Board would also be required to Continue reading ›

Starting a Telemedicine Practice

March 26, 2026 | Little Health Law

Our healthcare and business law firm works with providers who would like to start their own telemedicine practice, especially since the COVID-19 Pandemic. Our firm has previously posted several blogs about telemedicine practice, such as UPDATE: Can You Create a Patient-Provider Relationship Through Telemedicine? on December 18, 2025, which gives an updated overview on how a patient-provider relationship can be created in Georgia through telemedicine. This blog post discusses important initial considerations that providers should consider before starting a telemedicine practice. If you are starting a telemedicine practice or would like to discuss this blog post, you may contact our healthcare law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

State Telemedicine Laws Normally State that a Provider Is Practicing Medicine in the State Where the Patient Resides.

States have laws governing telemedicine, and statutes, such as in Florida, for example, normally state that providers are considered to be practicing medicine in the state where the patient resides. Accordingly, for a practitioner to be conducting telemedicine in a state, the practitioner will need to have Continue reading ›