News & Analysis as of

Cost-Sharing Out-of-Pocket Expenses

Seyfarth Shaw LLP

Agencies Release 2026 Out-of-Pocket Limits and 2025 Limits for Health FSAs

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Recently HHS issued a memorandum announcing the maximum annual limitation on cost sharing (a/k/a out-of-pocket maximum) for 2026 and the IRS issued Rev. Proc. 2024-40 announcing the cost-of-living adjustments to certain...more

Ballard Spahr LLP

Prescription for Chaos: Copay Accumulator Programs Called Into Question

Ballard Spahr LLP on

Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more

Goodwin

Federal Court Strikes Down Copay Accumulator Programs

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On September 29, 2023, the U.S. District Court for the District of Columbia vacated a Trump-era rule from 2021 that allowed insurers to exclude drug manufacturer co-pay support coupons and assistance from a patient’s annual...more

Mintz - Health Care Viewpoints

Mintz IRA Update — Other Key IRA Programs and Developments: The Medicare Prescription Drug Inflation Rebate Program and Maximum...

Although most of the recent focus around the implementation of the Inflation Reduction Act (“IRA”) by the press and industry stakeholders has been on the Medicare Drug Price Negotiation Program, the IRA has several other...more

MoFo Life Sciences

Supreme Court Denies Review Of Cost Sharing Assistance Program

MoFo Life Sciences on

The U.S. Supreme Court recently declined to review a Second Circuit decision that blocked Pfizer from implementing a cost sharing assistance program. Pfizer had sought to cover out-of-pocket expenses for financially eligible...more

Holland & Knight LLP

OIG Advisory Opinion Highlights Further Concerns for Patient Assistance Programs

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Patient assistance programs (PAPs) that seek to subsidize patient co-payments for drugs covered by Medicare may involve compliance challenges. A recent U.S. Department of Health and Human Services (HHS) Office of Inspector...more

Polsinelli

New Federal Surprise Billing Prohibition and Its Implication on State Laws

Polsinelli on

On July 1, 2021, the Biden-Harris Administration issued “Requirements Related to Surprise Billing; Part 1,” an interim final rule (IRM) that will restrict health care providers and facilities from sticking patients with...more

Hogan Lovells

No Surprises Act prohibits balance billing, creates arbitration process for out-of-network providers

Hogan Lovells on

Effective January 1, 2022, the “No Surprises Act” signed into U.S. law as part of H.R. 133, “Consolidated Appropriations Act, 2021,” implicates (1) emergency services provided by non-participating providers at participating...more

McAfee & Taft

RADICAL new transparency rules likely to apply to your health plan in one year

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New rules published last month likely require your employer health plan to phase-in certain disclosures over a three-year period beginning in one year: 1. January 1, 2022 (three files must be disclosed): For plan years...more

Bricker Graydon LLP

Surprise COVID-19 medical bills: What providers can and cannot do

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Providers have faced many challenges since the start of the COVID-19 pandemic and have needed to quickly react to changing laws and regulatory requirements impacting their operations. One such change is the restrictions on...more

Seyfarth Shaw LLP

Sad Day for Coupon-Clippers

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Seyfarth Synopsis: Recently, the Trump Administration issued its proposed Notice of Benefit & Payment Parameter for 2021 regulations....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Employers May Need to Provide Cost Data Under Proposed ACA Rules

Employer-sponsored health plans and health insurers may be required to post online - and to provide participants upon request - a range of pricing and cost-sharing information beginning in 2021. Proposed Affordable Care...more

Holland & Knight LLP

OIG Issues Letter Declining to Impose Administrative Sanctions for Provision of Certain Free Drugs

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On Jan. 4, 2018, the HHS Office of Inspector General (OIG) issued an open letter containing guidance regarding the provision of certain free drugs to federal healthcare program beneficiaries. Specifically, the OIG stated that...more

K&L Gates LLP

K&L Gates Triage: An Insider’s Perspective on the Health Care Debate in Washington, DC

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In this episode of Triage, Amanda Makki and Corbin Santo of the K&L Gates Public Policy and Law practice group discuss several fundamental issues that are currently at the center of the health care debate in Washington, DC....more

Proskauer - Employee Benefits & Executive...

Updated Health Care Reform Legislation Comparison Chart

The chart below compares key provisions of the Affordable Care Act (ACA), the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BCRA). This chart is current as of July 13, 2017, and as of that date,...more

Buchalter

Are You Ready for AB 72?

Buchalter on

To protect patients from receiving an unexpected surprise bill when they seek care at in-network facilities from out-of-network providers, Governor Brown signed AB 72: California’s surprise out-of-network law. The new law...more

McGuireWoods LLP

Washington Healthcare Update

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This Week: 21st Century Cures Legislation Passes House in Bipartisan Vote... CMS Releases Proposed CY 2016 Home Health Prospective Pay Rule... CMS Releases Final CY 2016 Hospital Outpatient Prospective Payment System (OPPS)...more

Proskauer - Employee Benefits & Executive...

Reminder: Non-Grandfathered Plans Must Implement Embedded Out-of-Pocket Maximums

As employers and plans prepare for 2016 open enrollment, they must be sure to address in their benefit design and with their third party vendors the new embedded out-of-pocket maximum limitations on individuals that were...more

McAfee & Taft

New ruling limits out-of-pocket expenses at individual level in 2016

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Most health plan and health insurance policies include strategies that require persons covered under them to share in the costs that are paid. This strategy, often referred to as cost-sharing, serves two purposes. First, it...more

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