IHA Daily Briefing: January 9

340B Rebate Model Pilot Program Implementation Halted
Following the U.S. District Court of Maine's preliminary injunction issued on Dec. 29, 2025, which temporarily blocked the implementation of the U.S. Dept. of Health and Human Services (HHS) 340B Rebate Model Pilot Program that was scheduled to begin on Jan. 1, this week the U.S. Court of Appeals for the First Circuit denied HHS's motion for a stay of the injunction pending its appeal. This means that the 340B Rebate Pilot remains on hold.

Notably, the District Court's order prohibits HHS from implementing the Rebate Pilot nationwide, rather than only prohibiting implementation against the organizations-including the American Hospital Association-that filed the lawsuit against HHS alleging it violated the Administrative Procedures Act (APA).

In issuing the preliminary injunction, the District Court recognized that HHS has the authority to achieve statutory objectives through a rebate model but found that the plaintiffs were likely to succeed in their claim that HHS violated the APA in doing so, at least on the current record. The District Court may ultimately invalidate the Rebate Pilot, but HHS could still correct its errors and implement a revised Rebate Pilot in conformance with the APA.

Staff contact: Mike Woods

IDPH Issues Emergency Rules on Health Care Sanctity and Privacy Act Implementation
The Illinois Dept. of Public Health (IDPH) has issued emergency rules implementing HB 1312 /PA 104-0440, which created the Health Care Sanctity and Privacy Act. A copy of the rules can be found here.

In November, IHA published a detailed member memo summarizing HB 1312/PA 104-0440. See a full copy of the memo here. In December, IHA issued a memo explaining how hospitals should submit their policies and provided a copy of the template for the notice that must be posted, in a conspicuous place within the hospital, which is accessible to patients, employees, and visitors, in the predominant language or languages spoken in the hospital's service area. A copy of IHA's Dec. 24 memo is here.

Staff contact: Karen Harris

General Assembly to Begin 2026 Spring Session Next Week
The Illinois General Assembly is set to begin the 2026 Spring Session next week. The Illinois Senate will reconvene Tuesday, Jan. 13, through Thursday, Jan. 15. No legislation is positioned for consideration in the Senate next week, and no committee hearings are scheduled. The House of Representatives will reconvene the following week, from Tuesday, Jan. 20, through Thursday, Jan. 22.

Deadlines will approach quickly in the new year. Jan. 16 is the deadline to request a bill be drafted for Spring consideration. Feb. 6 is the deadline to file legislation.

Illinois Ranked #1 for Workforce Development in Midwest
Today, Gov. JB Pritzker and the Illinois Dept. of Commerce and Economic Opportunity (DCEO) announced that Site Selection Magazine, the leading economic development publication, named Illinois #1 for workforce development in the Midwest and #3 in the nation for 2026 - up from #2 regionally and up from #4 nationally. The workforce development rankings, based on an updated index of criteria, "take into account that workforce's prowess, whether measured by credentials, certificates and degrees; technical skills and productivity; or something equally important to employee and employer alike: return on investment." They combine metrics from multiple organizations, including the Bureau of Labor Statistics, SkillsUSA, Lumina Foundation, ACT, and Strada.

IDPH to Host Jan. 15 Fast Phact Webinar on Cannabis as Medicine
The Illinois Dept. of Public Health (IDPH) hosts clinician-focused, interactive Fast Phact sessions designed to provide timely insight into emerging and high-impact public health issues with direct implications for clinical practice and health systems.

"Cannabis as Medicine: What Every Clinician Should Know" will be the next installment in the series, held from noon-1 p.m. CT on Jan. 15.

Participants will:

• Examine the evidence behind cannabinoids for pain and other conditions;

  Learn how to assess bias and study quality;

• Review real-world patient cases involving cardiovascular risk, cannabis hyperemesis syndrome, and cannabis use disorder; and

• Explore practical challenges clinicians face, including advising patients amid supply chain uncertainties.

Healthcare professionals from all disciplines are encouraged to attend. Click here to register. Up to one hour of Continuing Medical Education (CME) credit is available.