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Surprise, Surprise! No Surprise Billing Regulations Upheld

The Fifth Circuit Court of Appeals recently upheld regulations defining the qualifying payment amount (QPA). The QPA is a key factor in determining how much individuals and health plans must pay out-of-network providers in...more

Health Plan Compliance Deadlines Draw Near

Regulations under Section 1557 of the Affordable Care Act and HIPAA will require health plans and health care providers to take action in the coming months to meet new requirements. Health plan sponsors and providers that...more

2024 HIPAA Developments

Over the course of the past few months, the Office of Civil Rights (OCR) and the Office of the National Coordinator for Health Information Technology (ONC), both of which are divisions of the U.S. Department of Health and...more

Final Section 1557 Rules: Highlights for Health Plan Sponsors

The U.S. Department of Health and Human Services (HHS) has issued final regulations on the nondiscrimination rules set forth in Section 1557 of the Affordable Care Act. The new rules apply to certain group health plans, as...more

HIPAA Breach Notifications – A Question of Timing

You are the HIPAA privacy official of a hospital or health plan (a covered entity under HIPAA). You receive an email from a vendor that handles protected health information (a business associate), informing you that one month...more

HHS Announces Temporary Copay Accumulator Non-Enforcement Policy

The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....more

No Surprises, But Much Uncertainty: The Status of CAA Billing Rules

Summary - The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy....more

Details Upon Details: Compliance Under MHPAEA’s New Proposed Regulations

Summary - The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed...more

New Mental Health Parity Guidance Issued

Summary - On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health...more

Meet Me at the Corner of No Surprises and …

Summary - The Departments of Labor, Health and Human Services, and the Treasury have issued guidance that coordinates application of the No Surprise Billing rules under the Consolidated Appropriations Act, 2021, with the...more

Preventive Care Rules Remain in Place for Now

The Fifth Circuit Court of Appeals has stayed the broad application of a district court decision that would have invalidated a number of preventive care requirements under the Affordable Care Act. As a result, health plans,...more

FAQs Provide Guidance on Preventive Care

Summary - The Departments of Labor, the Treasury, and Health and Human Services have jointly issued FAQs that address the requirement to cover the full cost of certain preventive care services in view of the recent ruling...more

Court Invalidates Certain Preventive Care Requirements

Summary - Health plans and insurance policies may no longer be required to cover the full cost of preventive care that carries an A or B rating by the U.S. Preventive Services Task Force (USPSTF), following a recent ruling...more

Spring Cleaning: Preparing for the COVID Emergency’s End

Summary - The almost three-year-old COVID-19 national emergency and public health emergency declarations (Declarations) are slated to expire May 11, 2023....more

Beware the Bright Lights

The Office of Civil Rights of the Department of Health and Human Services has announced settlements with three different Boston-area hospitals for allegedly compromising the privacy of protected health information by inviting...more

HIPAA: Privacy Required, Even When Information Goes Public

A celebrity collapses on stage and is rushed to the hospital. Rumors race through social media faster than the ambulance can navigate city streets. Was it exhaustion? Was it her heart? Was there a gunshot? ...more

Beware of Phishing Email Disguised as Official OCR Audit Communication

The Office of Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) has posted an alert (and a follow-up alert) warning health plans, health care providers, and their vendors of a mock communication...more

IRS Extends ACA Reporting Deadline

The IRS has extended the deadline for furnishing 2016 Forms 1095-C and 1095-B to individuals by 30 days to March 2, 2017. The reprieve offers welcome relief to employers, health insurers, and other plan sponsors who would...more

Guidance Addresses Mental Health Parity

The U.S. Departments of Labor, Health and Human Services, and the Treasury have issued a set of Frequently Asked Questions and Answers that, among other things, implement certain of the recommendations included in a report...more

Final Regulations on Short-Term Health Plans Under the Affordable Care Act

The U.S. Departments of Labor, Health and Human Services, and the Treasury have finalized regulations under the Affordable Care Act (ACA) that address certain exceptions under the ACA. Among other things, the regulations...more

Hot Topics in Employer Health Benefits

As we start looking forward to 2017, and as many employers head into annual enrollment periods this fall, employers need to be aware of recent changes in the law that have a significant impact on health benefit plans. This...more

IRS Proposes Adjustments in Individual Mandate Reporting

The IRS has issued proposed regulations on the individual mandate reporting requirements under section 6055 of the Internal Revenue Code. To a significant degree, the new regulations reflect guidance previously published by...more

Further Guidance on ACA Market Reforms

Following up on the issuance of final regulations on various market reform provisions under the Affordable Care Act (ACA), the IRS has issued a notice with Questions and Answers that take a more detailed look at specific ACA...more

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