News & Analysis as of

Final Rules Patient Protection and Affordable Care Act (PPACA) Medicare Advantage

McDermott Will & Emery

The ACA 1557 Final Regulations: Plans and Plan Sponsors as Covered Entities

McDermott Will & Emery on

In a recent On the Subject (available here), we reported on the impact of the final rule (final rule) interpreting Section 1557 of the Affordable Care Act (ACA) on self-funded group health plans that contract with licensed...more

McDermott Will & Emery

CMS Issues Guidance on Usage of AI in Making Coverage Determinations

McDermott Will & Emery on

On February 6, 2024, the US Centers for Medicare & Medicaid Services (CMS) issued a letter to all Medicare Advantage (MA) organizations and Medicare-Medicaid plans. The letter covered frequently asked questions and answers...more

Sheppard Mullin Richter & Hampton LLP

CMS Includes MAOs in Data Exchange and Prior Authorization Requirements

The Centers for Medicare and Medicaid Services (“CMS”) issued a proposed rule, “Advancing Interoperability and Improving Prior Authorization Processes” (the “Proposed Rule”), that is intended to improve patient and provider...more

Jones Day

D.C. District Court Vacates 60-Day Medicare Advantage Overpayment Rule

Jones Day on

The Situation: In 2016, several Medicare Advantage ("MA") organizations challenged a 2014 final rule promulgated by the Center for Medicare Services ("CMS") that broadly subjected MA organizations to potential liability under...more

Baker Donelson

OIG Finalizes CMP Regulations, Largely as Proposed

Baker Donelson on

On December 7, 2016, the Department of Health and Human Services, Office of Inspector General (OIG) finalized [PDF] its proposal to update the civil monetary penalty (CMP) regulations – namely, incorporate new CMP authorities...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

King & Spalding

CMS Issues Pared-Down Final Rule on Medicare Part D and Medicare Advantage

King & Spalding on

CMS recently issued a Final Rule with respect to the Medicare Part D and Medicare Advantage programs (the “Final Rule”) implementing certain Affordable Care Act provisions. The Final Rule follows a January 10, 2014 Notice of...more

Cozen O'Connor

Health Care Reform Implementation Update - February 26, 2014

Cozen O'Connor on

Though Congress was in recess this past week, congressional staff was hard at work continuing to consider ways to prevent a cut to Medicare providers’ payment rates that will be triggered by the sustainable growth rate...more

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