Key Takeaways Medspas and other entities operating in the aesthetic space that dispense or administer prescription drugs should assess whether they have obligations as dispensers under the DSCSA and ensure they have policies, procedures and controls in place to demonstrate compliance with applicable requirements. To avoid the deficiencies cited in the warning letter, dispensers should focus on strengthening supply chain controls, maintaining complete product records and ensuring operational readiness for FDA inspection. Dispensers that receive a Form FDA 483 documenting observations of potential violations after an FDA inspection should act immediately to develop a thorough response with supporting documentation. On April 1, 2026, the FDA issued a warning letter to Pure Indulgence Aesthetics (Pure Indulgence), a Texas-based medical spa. Notably, this is the first

2026 is shaping up to be a pivotal year for health care reimbursement. From major CMS payment rules to evolving disclosure requirements, AI scrutiny, and mounting pressure on providers across the care continuum, the 2026 Health Care Reimbursement Newsletter highlights the developments you need to understand now to stay ahead. In this issue: 2025 Wrap-Up: Key CMS Enrollment Changes and Disclosure Developments What Hospitals & ASCs Need to Know About the 2026 Outpatient Prospective Payment and ASC Final Rule Durable Medical Equipment Update 2026 Medicare Physician Fee Schedule Final Rule Highlights Forecasting Medicaid Challenges for Providers in 2026 Rural Health Providers Face a Tough Financial Road in 2026 – Will the Rural Health Transformation Program Save Them? Medicare Advantage Reimbursement Implications from the 2027 Proposed Rule Looking Ahead to 2026: CMS