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Health Care Reform 2017: Substance, Process, and Timeline

President-elect Donald J. Trump campaigned on a promise to “repeal and replace” the Affordable Care Act (“ACA”). For several years, the newly reelected Republican majority in Congress has likewise identified ACA repeal as a...more

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

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

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

“Next-Generation ACO” Model Is CMS’s Newest Effort to Encourage More ACO Risk

On March 10, 2015, the Centers for Medicare & Medicaid Services’ (“CMS’s”) Center for Medicare and Medicaid Innovation (“Innovation Center”) announced a demonstration project incorporating new risk models for reimbursement of...more

CMS Takes a Measured Approach to Medicare Advantage and Part D Plan Payment Rates and Policy Changes for 2016

Increased Part D Drug Costs Set the Stage for Higher Beneficiary Premiums - The Advance Notice (“Advance Notice”) of Methodological Changes for Calendar Year (“CY”) 2016 for Medicare Advantage (“MA”) Capitation Rates,...more

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

Medicare Shared Savings Program Proposed Rule: Enough Incentive to Encourage More ACO Risk?

On December 1, 2014, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule (“Proposed Rule”) setting forth long-anticipated changes to the Medicare Shared Savings Program (“MSSP”), including payments...more

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

OIG Supplemental Advisory Bulletin on Patient Assistance Programs Leaves Open Questions for High-Cost Breakthrough Drugs in...

On May 21, 2014, the Office of the Inspector General ("OIG") of the Department of Health and Human Services issued a Supplemental Special Advisory Bulletin ("Supplemental Bulletin") addressing the risks that Independent...more

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

2015 Payment Notice and Final Call Letter: A Mixed Bag for Medicare Advantage and Prescription Drug Plans

On April 7, 2014, the Centers for Medicare & Medicaid Services ("CMS") released the Announcement of Calendar Year ("CY") 2015 Medicare Advantage ("MA") Capitation Rates and Medicare Advantage and Part D Payment Policies...more

CMS Proposes Significant Rate Cuts and Other Changes to Medicare Advantage and Prescription Drug Plans

The Advance Notice ("Advance Notice") of Methodological Changes for Calendar Year ("CY") 2015 for Medicare Advantage ("MA") Capitation Rates, Part C and Part D Payment Policies and 2015 Call Letter was released by the Centers...more

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