Anne W. Hance

Anne W. Hance

McDermott Will & Emery

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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 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

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 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

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