Health Care Today | Health Law Blog

In 2019, the Centers for Medicare and Medicaid Services (CMS) issued draft guidance on hospital co-location (when hospitals share space and resources with other health care entities). We previously summarized that draft guidance here. On November 12, 2021, CMS issued its final guidance and — surprise! — it changed quite a bit.

As originally drafted, the Illinois Freedom to Work Act (IFWA) only barred employers from entering into non-compete agreements with “low wage employees,” i.e., those making no more than minimum wage or $13 per hour, whichever is greater. In 2022, the law is expanding to include broader limitations on non-competes and, for the first time, non-solicitation agreements.