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Transparency Patient Protection and Affordable Care Act (PPACA)

Gardner Law

CMS Audits on the Horizon: Prepare for Increased CMS Audits Under the Sunshine Act

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Historically, the Centers for Medicare and Medicaid Services (“CMS”) has not aggressively pursued enforcement activity under the Sunshine Act. However, this may change in 2024. Late last year, CMS updated its Open Payments...more

Ankura

The Focus of Federal Proposals on Pharmacy Benefit Management – 118th Congress

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Over the past several years, legislators across the country have focused their attention on Pharmacy Benefit Managers (PBMs) due to concerns expressed over a variety of industry practices. To date, there has been legislation...more

Arnall Golden Gregory LLP

UPDATE: CMS Finalizes Rule Requiring Greater SNF Ownership Transparency, Including Private Equity and REIT Disclosures, and...

The Centers for Medicare & Medicaid Services (“CMS”) released a final rule on November 15, 2023 (published on November 17, 2023) (the “Rule”), requiring greater skilled nursing facility (“SNF”) ownership transparency. The...more

Holland & Knight LLP

CMS Issues Final Rule on Ownership Transparency

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The Centers for Medicare & Medicaid Services (CMS) announced on Nov. 17, 2023, a final rule requiring skilled nursing facilities (SNFs) to publicly disclose additional ownership and management information. The rule was...more

Woodruff Sawyer

Agencies Issue Additional FAQs Regarding the Transparency in Coverage Final Rules

Woodruff Sawyer on

On September 27, 2023, the DOL, IRS, and HHS released FAQs About Affordable Care Act Implementation Part 61 (“FAQ Part 61”) which addresses lingering questions about enforcement of the Transparency in Coverage Final Rules...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Snell & Wilmer

Enforcement Back On: Departments Rescind Enforcement Relief for Machine Readable File Requirements under Transparency in Coverage...

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On September 27th, the Departments released FAQs about Affordable Care Act Implementation Part 61 (“FAQ 61”), announcing that the Departments are rescinding prior-issued enforcement relief for certain machine-readable file...more

Davis Wright Tremaine LLP

New FAQs Address No Surprises Act Impact on ACA Maximum Out-of-Pocket Limits and Facility Fee Transparency

Employers should be aware that the No Surprises Act has an impact on the maximum-out-of-pocket ("MOOP") limit for annual cost-sharing under the Affordable Care Act ("ACA") and facility fee transparency. The new set of...more

FordHarrison

Transparency in Coverage Requirements – Compliance Deadline Approaching

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Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022....more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Arnall Golden Gregory LLP

Proposal Calls for Increased Transparency of Ownership for Privately Owned Nursing Homes

Continuing the theme of increased transparency of ownership of nursing homes included in the 2010 Affordable Care Act, the White House issued a Fact Sheet titled “Protecting Seniors and People with Disabilities by Improving...more

Mintz - Employment Viewpoints

Health Plan Transparency and the Case for Welfare Plan Fiduciary Committees

The Consolidated Appropriations Act, 2021 (the “Act”) adopted a series of transparency requirements that apply to employer-sponsored group health plans. These transparency rules impose a series of new and complex obligations...more

Foley & Lardner LLP

Employer Checklist for New Health Plan Price Transparency Rules and CAA

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The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...more

Verrill

You Are Here: A Mall Directory for Healthcare Transparency Requirements

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The old adage “you can’t get where you’re going unless you know where you are” has never seemed more true than when applied to the current mélange of healthcare transparency guidance. Fortunately, a fading relic from...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Troutman Pepper

US Chamber of Commerce Files Lawsuit Challenging HHS's Health Plan Price Transparency Rule

Troutman Pepper on

The federal government’s push for greater price transparency in health care has been highly controversial among health care stakeholders. In 2020, the American Hospital Association (AHA) unsuccessfully challenged HHS’s “Price...more

Cozen O'Connor

US And Tyler Texas Chambers Of Commerce Sue Feds To Block Portions Of The Health Plan Transparency Rule

Cozen O'Connor on

Two chambers of commerce, the Chamber of Commerce the United States of America and the Tyler (TX) Area Chamber of Commerce, filed a lawsuit on August 10, 2021, in the US District Court for the Eastern District of Texas...more

Sheppard Mullin Richter & Hampton LLP

Biden Administration Finalizes Lower Out-of-Pocket Costs for Exchange Plans, Targets Health Equity and Access

The Biden Administration used the annual rulemaking that governs health plans sold on the Affordable Care Act’s exchanges to lower health care costs for consumers and improve access to health care. Part 2 of the Notice of...more

Bass, Berry & Sims PLC

Healthcare Policy Under the Biden Administration: Key Takeaways

Bass, Berry & Sims attorney Angela Humphreys—Chair of the Healthcare Practice and Co-Chair of the Healthcare Private Equity Team—sat down virtually with Paul Keckley—a healthcare policy analyst, industry expert and Managing...more

Shumaker, Loop & Kendrick, LLP

Client Alert: District Court of Appeals Upholds Hospital Charges Transparency Rule

The Affordable Care Act of 2010 required that hospitals annually establish and make public a list of its “standard charges.” Health and Human Services (HHS) historically allowed hospitals to comply by posting their charge...more

Alston & Bird

Impact of 2020’s Final Transparency Requirements on Employer-Sponsored Health Plans

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On October 29, 2020, the Centers for Medicare and Medicaid Services (CMS) along with the Department of Labor (DOL) and Treasury issued a final rule on price transparency to enable patients to accurately predict health care...more

King & Spalding

Senator's Letter Focuses on Nonprofit Hospitals' Tax-Exempt Status and Price Transparency

King & Spalding on

Last week, Iowa Senator Chuck Grassley wrote a letter to the United States Senate Committee on Finance (the Letter) concentrating on nonprofit hospitals’ debt collection and financial assistance practices and price...more

Foley & Lardner LLP

An Irony of Ironies – The Final ACA Price Transparency Rule

Foley & Lardner LLP on

Some found it somewhat ironic when, only one week before the Acting Solicitor General appeared before the United States Supreme Court to argue that Congress effectively repealed the entire Affordable Care Act (“ACA”) in...more

Maynard Nexsen

Transparency in Pricing Trend Continues with New Federal Rule that Applies to Health Plans

Maynard Nexsen on

On October 29, 2020, the Department of Health and Human Services (HHS), the Department of Treasury, and the Department of Labor issued a new “transparency in coverage” final rule that is focused on insurance companies and...more

McDermott Will & Emery

Agencies Issue Final Employer Healthcare Price Transparency Rule

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On October 29, 2020, the US Departments of Health and Human Services, Labor and Treasury (collectively, the Departments) issued the Transparency in Coverage final rule (the Rule), along with a fact sheet, setting forth...more

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