Anne W. Hance

Anne W. Hance

McDermott Will & Emery

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2015 Notice of Benefit and Payment Parameters

The Centers for Medicare & Medicaid Services (CMS or the agency) kicked off a flurry of springtime regulatory activity for health insurance issuers with publication of the final Notice of Benefit and Payment Parameters for...more

3/24/2014 - Affordable Care Act CMS Employee Benefits Health Insurance Exchanges Healthcare Healthcare Reform

CMS Indicates Select Controversial Part D Proposals Will Not Be Finalized

Acknowledging concerns regarding some proposals in the January 2014 proposed rule for the Medicare Advantage and Part D Programs, the Centers for Medicare & Medicaid Services states it does “not plan to finalize” certain...more

3/17/2014 - CMS Healthcare Medicare Medicare Part D

CMS Proposes to Restrict Diagnoses from Home Visits for Medicare Advantage Risk Adjustment

The Centers for Medicare and Medicaid Services has proposed to limit how Medicare Advantage Organizations can use in-home wellness or risk assessment visits of their enrollees to affect the risk adjusted payments they...more

2/25/2014 - CMS Healthcare Healthcare Reform Home Health Care Medicare Advantage

CMS Proposed Rule Would Modify Risk Adjustment Data Collection, Data Validation Audits with Some Material Effects

The Centers for Medicare & Medicaid Services’ proposal for risk adjustment data collection demonstrates the agency’s continued concern that Medicare Advantage Organizations’ activities are resulting in more “intense” coding,...more

1/29/2014 - Audits CMS Data Collection Healthcare

CMS Proposes Significant Changes to Medicare Part D Program’s Administration

The Centers for Medicare & Medicaid Services proposes significant changes to several key Medicare Part D Program components, such as the “any willing pharmacy” contracting requirement, that will affect all industry...more

1/24/2014 - CMS Healthcare Healthcare Reform Medicaid Medicare Medicare Part D Pharmacies

Proposed Overpayment Reporting Requirements for MA and Part D Programs May Increase False Claims Act Liability

The Centers for Medicare & Medicaid Services continues to take an expansive view of the overpayment refund requirement, which in turn can give rise to False Claims Act liability for Medicare Advantage Organizations and Part D...more

1/24/2014 - CMS False Claims Act Medicaid Medicare Medicare Part D Overpayment Reporting Requirements

CMS Proposed Rule Reflects Increased Sophistication in Administration of MA/Part D Programs

Addressing issues ranging from participation in Part D Plan pharmacy networks to compliance training for so-called first-tier, downstream and related entities, the Proposed Rule covers numerous topics with varying degrees of...more

1/22/2014 - CMS Healthcare Medicare Medicare Part D

ACA Proposed Rule to Require Health Insurers to Certify Compliance with HIPAA Electronic Transaction Requirements

The U.S. Department of Health and Human Services issued a proposed rule to implement the ACA requirement that health insurers and other HIPAA-covered health plans certify compliance with the standards and operating rules for...more

1/9/2014 - Affordable Care Act EFTs Healthcare Healthcare Reform HHS HIPAA Qualified Health Plans

HHS Proposes Clarifications for Market Reform Regulations and New Exchange-Related Obligations But Leaves Key Questions Unanswered

The proposed rule imposes new requirements on health insurance issuers offering Qualified Health Plans through Health Insurance Exchanges and clarifies other obligations for various market reforms and the Premium...more

6/21/2013 - Affordable Care Act Contractors False Claims Act Health Insurance Exchanges HHS Qualified Health Plans Recordkeeping Requirements

CMS Medicare MLR Final Rule Creates New Obligations and Risks

The Centers for Medicare & Medicaid Service’s release of the final Medicare medical loss ratio regulations allows Medicare Advantage Organizations and Part D Plan Sponsors to evaluate their operations in order to come into...more

6/4/2013 - CMS Compliance Enforcement Actions Final Rules Health Plan Sponsors Medicare Part D Payment Plans Subcontracts

CMS Announces CY 2014 MA and Part D Rates with Change to Growth Rate Estimates

The Centers for Medicare & Medicaid Services (CMS) released the announcement of CY 2014 payment rates on April 1, which included its change in position regarding the assumption of the "doc fix" in estimates of Medicare...more

4/5/2013 - CMS Fee-for-Service Fees Medicare Medicare Advantage Pharmacies Risk Assessment

Staying the Course: HHS Finalizes the Essential Health Benefits Regulations for 2014

The U.S. Department of Health and Human Services (HHS) Essential Health Benefits Final Rule and actuarial value regulations offer few surprises and much needed certainty to enable group health plans and health insurance...more

2/27/2013 - Cost-Sharing Employer Group Health Plans Essential Health Benefits Health Savings Accounts HHS HRA Prescription Drug Coverage

CMS Releases 2014 Advance Notice and Proposed MA and Part D Program MLR Regulations

On February 15, 2013, the Centers for Medicare & Medicaid Services released for comment two key documents affecting the Medicare Advantage (MA) and Part D Programs: (1) the Advance Notice of Methodological Changes for...more

2/25/2013 - CMS Fee-for-Service Medicaid Medical Loss Ratio Medicare Medicare Advantage Medicare Part D MLR Rebate

The American Taxpayer Relief Act of 2012 and Anticipated Medicare and Medicaid Payment Reforms

On January 1, 2013, the U.S. Congress approved the American Taxpayer Relief Act of 2012 (the Act), concluding a protracted debate on how to prevent the United States from falling over the proverbial “fiscal cliff.” President...more

1/9/2013 - American Taxpayer Relief Act Fiscal Cliff Income Taxes Medicaid Medicare

Essential Health Benefits Proposed Rule: Additional Detail with Few Surprises

The essential health benefits proposed rule, issued on November 20, 2012, defines the so-called Essential Health Benefits Package, composed of essential health benefits, cost-sharing limitations and actuarial value...more

12/3/2012 - Affordable Care Act Essential Health Benefits HHS Qualified Benefit Plans

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