Jeremy Earl

Jeremy Earl

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 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

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

HHS Clarifies that ACA Qualified Health Plans are Not Subject to Federal Anti-Kickback Statute; Expresses Concern about Providers...

The U.S. Department of Health and Human Services recently announced that Qualified Health Plans (sold on and off the Exchanges) are not “Federal health care programs” for purposes of the federal anti-kickback statute. The...more

11/6/2013 - Affordable Care Act Anti-Kickback Statute Health Insurance Exchanges HHS Kickbacks Open Enrollment Qualified Health Plans

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

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

CMS Announces Participants in Bundled Payment Initiative

The U.S. Centers for Medicare & Medicaid Services (CMS) recently announced the health care organizations chosen to participate in the Bundled Payments for Care Improvement (BCPI) Initiative. The BCPI Initiative represents a...more

2/7/2013 - BPCI Bundled Payments CMS Fee-for-Service Healthcare Medicaid Medicare

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