When Congress created the Part D benefit for Medicare beneficiaries, it also required group health plan sponsors and certain other entities to notify Medicare-eligible participants and the Centers for Medicare & Medicaid...more
On May 13, 2024, the Eleventh Circuit Court of Appeals held that certain federal non-discrimination protections apply to transgender individuals in the group health plan (insured and self-insured) context. In particular, the...more
On June 28, 2024, in a 6-3 decision, the Supreme Court overturned Chevron v. Natural Resources Defense Council (“Chevron”), the most-cited case in administrative law. Chevron established a framework for how the federal...more
On May 6, 2024, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) and the Centers for Medicare and Medicaid Services (“CMS”) published the long-awaited Nondiscrimination in Health Programs...more
On May 9, 2024, the Biden Administration continued its push to update and modernize federal nondiscrimination protections by publishing revised regulations (the “Final Rule”) that amend the Department of Health and Human...more
On March 28, 2024, the Departments of Labor, Treasury, and Health and Human Services (the “Tri-Agencies”) issued final regulations on short-term, limited-duration insurance (“STLDI”), hospital and other fixed indemnity...more
On January 16, 2023, the Department of Health and Human Services (“HHS”) dropped its appeal of the U.S. District Court for the District of Columbia’s September 29, 2023 decision that vacated a portion of the 2021 Notice of...more
In early November, the Centers for Medicare and Medicaid Services (“CMS”) published the contract year 2025 proposed rulemaking (“Proposed Rule”) for Medicare Advantage (“MA”) and Part D sponsors. The Proposed Rule previews...more
On September 29, 2023, the U.S. District Court for the District of Columbia vacated the 2021 Notice of Benefit and Payment Parameters (“2021 NBPP”) amendments to Affordable Care Act regulations. The amendments permitted (but...more
Recently, the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”), HHS’s Centers for Medicare & Medicaid Services (“CMS”), and Congress have focused attention on the role of managed care...more
On July 25, 2023, the Departments of Health and Human Services, Labor and Treasury (“Tri-Agencies”) issued sweeping new guidance on the Mental Health Parity and Addiction Equity Act (“MHPAEA”), including a Proposed Rule, a...more
On July 7, the Departments of Labor, Treasury, and Health and Human Services (the “Tri-Agencies”) published a long-anticipated proposed rule (“Proposed Rule”) that...more
CMS published the Calendar Year (“CY”) 2024 Medicare Advantage (“MA”) Capitation Rates and Part C and Part D Payment Policies (“Rate Announcement“) on March 31 and, five days later, issued the MA and Part D final rule for...more
More than four years after it was proposed, on February 1, 2023 the Centers for Medicare & Medicaid Services (CMS) published the long-awaited risk adjustment data validation (RADV) Final Rule (Final Rule) that will affect...more
2/24/2023
/ Audits ,
Centers for Medicare & Medicaid Services (CMS) ,
Extrapolation ,
Fee-for-Service ,
Final Rules ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
Medicare ,
Medicare Advantage ,
Medicare Advantage Organizations (MAOs) ,
Risk Adjustment Formula
On Tuesday, December 13, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule (“New Proposed Rule”) to improve the prior authorization process and advance interoperability for Medicare Advantage...more
12/22/2022
/ Centers for Medicare & Medicaid Services (CMS) ,
Children's Health Insurance Program (CHIP) ,
Comment Period ,
Federally Facilitated Exchanges ,
Health Insurance ,
Healthcare ,
Managed Care Contracts ,
Medicaid ,
Medicare ,
Medicare Advantage Organizations (MAOs) ,
Prior Authorization ,
Proposed Rules ,
Qualified Health Plans
On August 4, 2022, the Biden Administration published its long-anticipated proposed rulemaking on Affordable Care Act (“ACA”) Section 1557’s nondiscrimination in health programs and activities requirements (“Proposed Rule”)....more