Helaine Fingold

Helaine Fingold

Epstein Becker & Green

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Nondiscrimination Standards Under ACA Section 1557: Now Is the Time to Act

Health insurers and group health plan sponsors must closely review the final rule titled “Nondiscrimination in Health Programs and Activities” (“Final Rule”) implementing Section 1557 of the Affordable Care Act (“ACA”) that...more

9/16/2016 - Affordable Care Act Anti-Discrimination Policies Covered Entities Employer Group Health Plans Final Rules HHS Insurance Industry

MACRA Proposed Rule: CMS Provides Details on Implementing Medicare’s New Quality Payment Program

On May 9, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule addressing the implementation of physician payment reforms included in the Medicare Access and CHIP Reauthorization Act of 2015...more

5/31/2016 - Alternative Payment Models (APM) CMS Medicare Access and CHIP Reauthorization (MACRA) MIPS PQRS

Mental Health Parity Final Rule for Medicaid and CHIP: Few Changes from the Proposed Version

On March 30, 2016, the Centers for Medicare & Medicaid Services (“CMS”) published its long-awaited final rule (“Final Medicaid Parity Rule” or “Final Rule”) implementing the Paul Wellstone and Pete Domenici Mental Health...more

4/25/2016 - Affordable Care Act CHIP CMS Mental Health Parity Rule MHPAEA

Doing the Cha-Cha on Exchange Rules: CMS Moves Forward on Standardized Plan Offerings but Steps Back from Instituting Minimum...

On March 8, 2016, the Centers for Medicare & Medicaid Services (“CMS”) released a final rule titled “Patient Protection and Affordable Care Act; CMS Notice of Benefit and Payment Parameters for 2017” (“Final Rule”)[1] setting...more

3/17/2016 - Affordable Care Act CMS Final Rules Health Insurance Exchanges Qualified Health Plans

CMS Proposes Modest Increases to Medicare Advantage and Part D Plan Payment Rates Accompanied by Significant Revisions to Risk...

The Advance Notice (“Advance Notice”) of Methodological Changes for Calendar Year (“CY”) 2017 for Medicare Advantage (“MA”) Capitation Rates, Part C and Part D Payment Policies and 2017 Call Letter was released by the Centers...more

2/26/2016 - Affordable Care Act CMS Medicare Advantage Medicare Part D

CMS Continues to Strengthen Federal-Level Requirements for Qualified Health Plans

On December 2, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule titled “Patient Protection and Affordable Care Act; CMS Notice of Benefit and Payment Parameters for 2017” (“Proposed...more

12/21/2015 - Affordable Care Act CMS Health Insurance Proposed Regulation Qualified Health Plans

National Association of Insurance Commissioners Updates Model Network Adequacy Law to Address Narrow Networks and Surprise Bills

On November 22, 2015, the National Association of Insurance Commissioners (“NAIC”) approved an updated version of its Managed Care Plan Network Adequacy Model Act, now known as the Health Benefit Plan Network Access and...more

12/17/2015 - Affordable Care Act Guidance Update Health Insurance Exchanges Healthcare Insurance Industry NAIC

HHS Releases Far-Reaching Proposed Rule to Prohibit Discrimination by “Covered Entities” Pursuant to Section 1557 of the...

On September 8, 2015, the U.S. Department of Health and Human Services (“HHS”) published a proposed rule titled “Nondiscrimination in Health Programs and Activities” (“Proposed Rule”)[1] to implement the nondiscrimination...more

10/15/2015 - Affordable Care Act Covered Entities Discrimination Federally Facilitated Exchanges Health Care Providers Health Insurance Exchanges Healthcare HHS OCR Proposed Regulation Public Comment State Health Insurance Exchanges

New Value-Based Insurance Design Model for Medicare Advantage Plans Is the First of Multiple Medicare Plan Innovations Anticipated...

On September 1, 2015, the Centers for Medicare & Medicaid Services (“CMS”) announced[1] the opportunity for plan sponsors to test value-based insurance design (“VBID”) in the Medicare Advantage (“MA”) market. VBID refers to...more

9/14/2015 - Alternative Payment Models (APM) CMS Cost-Sharing Health Insurance Health Plan Sponsors Healthcare Medicare Advantage Medicare Part D Prescription Drugs Telemedicine

CMS Issues Broad-Reaching Proposals to Better Align Medicaid Managed Care with the Commercial and Medicare Markets

On May 26, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule (“Proposed Rule”) containing the first proposed revisions to the Medicaid managed care (“MMC”) program’s regulations in more than...more

6/3/2015 - Affordable Care Act CHIP CMS Comment Period Health Care Providers Health Insurance Healthcare Managed Care Contracts Medicaid

Mental Health Parity Requirements and Medicaid Plans: CMS Seeks Comment on Proposed Rule

On April 10, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published in the Federal Register a proposed rule (“Proposed Rule”) implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction...more

5/7/2015 - Affordable Care Act CHIP CMS Employer Group Health Plans Healthcare Managed Care Contracts MCOs Medicaid Medicare Mental Health Mental Health Parity Rule Proposed Regulation

CMS Announces Key 2015 Compliance Priorities for Federally Facilitated Exchange Plans

The Centers for Medicare & Medicaid Services (“CMS”) recently announced its 2015 key priorities for compliance reviews of qualified health plans (“QHPs”) offered in the federally facilitated marketplaces (“FFMs”). Through a...more

4/22/2015 - CMS Examination Priorities Healthcare Prescription Drugs Public Health Insurance Marketplace Qualified Health Plans

CMS Releases Updates to Its Medicare Advantage and Part D Plan Audit Protocols and Processes

On February 12, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released an updated version of its Medicare Advantage (“MA”) and prescription drug benefit (“Part D”) plan audit protocols and also announced the...more

3/2/2015 - Audits CMS Medicare Medicare Advantage Medicare Part D

Obama Administration Seeks Comments on Proposed Changes to Summary of Benefits and Coverage Document and Requirements

On December 30, 2014, the Departments of Health and Human Services, Labor, and the Treasury (collectively, “Departments”) issued a proposed rule (“Proposed Rule”) regarding the summary of benefits and coverage (“SBC”) for use...more

1/13/2015 - DOL Employer Group Health Plans Health Insurance HHS Proposed Regulation Safe Harbors Summary of Benefits and Coverage U.S. Treasury

Proposed Exemption of Limited Wraparound Coverage from Health Insurance Market Standards

On December 19, 2014, various federal agencies issued proposed regulations (“Proposed Regulations”) to amend the definition of “excepted benefits” to include certain limited wraparound health insurance coverage. “Excepted...more

1/7/2015 - Affordable Care Act ERISA Health Insurance Internal Revenue Code (IRC) PHSA Popular Proposed Amendments Proposed Regulation Wraparound Coverage

CMS Releases Key Proposals for the 2016 Qualified Health Plan Application Process

Stakeholders received insight on the Obama administration’s expected approach to the certification and oversight of qualified health plans (“QHPs”) on December 19, 2014, with the release by the Centers for Medicare & Medicaid...more

1/6/2015 - Certifications CMS Health Care Providers Healthcare Medicaid Medicare Public Health Insurance Marketplace Qualified Health Plans

CMS Seeks Comments on Proposed Enhancements and Modifications to the Star Ratings for Medicare Advantage and Part D Prescription...

On November 21, 2014, the Centers for Medicare & Medicaid Services (“CMS”) released a Request for Comments on proposed enhancements and modifications to the 2016 Star Ratings for Medicare Advantage (“MA”) and Part D...more

12/11/2014 - CMS Comment Period Medicare Advantage Medicare Part D

HHS Broadens Federal Controls Over Private Health Insurance Benefits and Operations

On November 21, 2014, the Obama administration released two proposed rules affecting health insurance issuers’ offering of private health insurance products both inside and outside of the public insurance exchanges...more

12/8/2014 - Affordable Care Act Barack Obama Essential Health Benefits Health Insurance Health Insurance Exchanges Healthcare Reform HHS Minimum Essential Coverage Multiemployer Plan Proposed Regulation

CMS Cost Sharing Reduction Reconciliation Reporting for QHPs

Qualified Health Plans (“QHPs”) and other stakeholders have until October 27, 2014, to comment on CMS’s proposed cost sharing reduction payment reconciliation reporting process. On Friday, September 26, 2014, CMS released...more

10/13/2014 - Affordable Care Act CMS Employee Benefits Healthcare Healthcare Reform Qualified Health Plans

CMS Requests Input on Health Plan Innovation Initiatives

Medicare Advantage (“MA”) plans, prescription drug plans (“PDPs”), and other stakeholders have until November 3, 2014, to provide input into the Centers for Medicare & Medicaid Services’ (“CMS’s”) consideration of potential...more

10/10/2014 - CMS Innovation Medicaid Medicare Advantage Prescription Drug Coverage Request For Information Supplemental Benefits Technology

HEAL Advisory: How Big Is Halbig? The Potential Effects of This Major Ruling Are Numerous and Significant

On July 22, 2014, the U.S. Court of Appeals for the D.C. Circuit and the U.S. Court of Appeals for the Fourth Circuit issued conflicting opinions on a key aspect of the Affordable Care Act ("ACA"). The cases are Halbig v....more

7/30/2014 - Affordable Care Act Appeals Barack Obama Employer Mandates En Banc Review Halbig v Burwell Health Insurance Health Insurance Exchanges Healthcare Reform King v Burwell SCOTUS Subsidiaries Tax Credits

CMS's Final Exchange and Insurance Market Standards Impact Qualified Health Plan Filings for 2015 and Beyond

On May 16, 2014, the Centers for Medicare & Medicaid Services ("CMS") released a final rule titled "Patient Protection and Affordable Care Act; Exchange and Insurance Market Standards for 2015 and Beyond" ("Final Rule")...more

6/9/2014 - Affordable Care Act CCIIO CMS Employer Mandates Federally Facilitated Exchanges Final Rules Health Insurance Exchanges Healthcare Popular Qualified Health Plans Small Business

CMS Scaled Back Changes to the Medicare Part D Prescription Drug and Medicare Advantage Programs, but Some Important Revisions...

On May 19, 2014, the Centers for Medicare & Medicaid Services ("CMS") released a final rule ("Final Rule") completing changes to the Medicare Program's outpatient prescription drug benefit ("Part D") program and the Medicare...more

5/22/2014 - CMS Disclosure Requirements Final Rules Medicaid Medicare Medicare Advantage Medicare Part D Prescription Drug Coverage Prescription Drugs

CMS Identifies Key Priorities for 2014 Compliance Reviews of Qualified Health Plans in the Federally Facilitated Marketplace

At a Centers for Medicare & Medicaid Services ("CMS") teleconference titled "Compliance Reviews in the Federally-Facilitated Marketplace" ("FFM"), which was held on April 10, 2014, CMS representatives discussed the agency's...more

4/14/2014 - Audits CMS Compliance Healthcare Medicaid Medicare Qualified Health Plans

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