Project Public Financing: Do’s and Don’ts

FERC’s issuance on June 18, 2026 of tailored show cause orders to all six regional grid operators means changes are likely coming to transmission interconnection rules for large load users. In order to comment, interested parties should file for intervention within 21 days of FERC’s recent issuance to secure the right to comment on RTO proposals when they are filed later.

The Cyber Incident Reporting for Critical Infrastructure Act of 2022 (“CIRCIA”) was passed in 2022. That law required covered entities who are part of so-called “critical infrastructure” to report cybersecurity incidents and ransomware payments to the Federal government. For cyber incidents, the law required reporting to CISA within 72 hours and for ransomware payments, the reporting is required within 24 hours—both tight turnarounds.

Healthcare providers and organizations may see significant changes in reimbursement, collections, payer mix, and financial performance as the Centers for Medicare & Medicaid Services (“CMS”) moves forward with implementation of its 2027 Notice of Benefit and Payment Parameters Final Rule governing the Health Insurance Marketplace. The final rule, combined with the expiration of enhanced ACA subsidies, is expected to reduce enrollment in comprehensive health insurance coverage and affect reimbursement, collections, and financial performance.