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Deciphering the Final AMP Rule – Key Provisions Impacting Pharmacies, PBMs, and Manufacturers

In late January, the Centers for Medicare & Medicaid Services (“CMS”) released the much anticipated Covered Outpatient Drugs Final Rule with Comment (the “AMP Final Rule”). The rule creates the regulatory definition for...more

Key Takeaways from OIG’s 2015 Work Plan

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released its Fiscal Year 2015 Work Plan on October 31. The Work Plan provides the OIG’s planned reviews and activities with respect to...more

OIG Special Advisory Bulletin Provides Guidance on Application of Federal Anti-Kickback Statute to Pharmaceutical Manufacturer...

In recent years, copayment coupon programs have become standard promotional practices for both large and small pharmaceutical manufacturers. Copayment coupons are typically offered to commercially insured patients in order to...more

CMS Declares Third Party Payment of QHP Premiums Not OK

On the heels of HHS’s recent announcement that qualified health plans (QHPs) purchased through the Affordable Care Act (ACA) insurance exchanges are not “federal health care programs” for purposes of the federal anti-kickback...more

HHS Announces That ACA Exchange Plans Are Not “Federal Health Care Programs”

In a surprising move late last week, HHS Secretary Kathleen Sebelius announced that qualified health plans (QHPs) purchased through the Affordable Care Act’s (ACA) insurance exchanges are not “federal health care programs”...more

Caution: Risk Adjustment Hurdles Facing Plans and Providers Under the Affordable Care Act

January 1, 2014 is fast approaching and regulators, payor organizations, providers, and many other interested parties are working to implement, operationalize, and participate in the state-based American Health Benefit...more

Will “Skinny” Health Care Plans Help Employers Escape Hefty Penalties?

Recent stories in the media on low-cost or “skinny” group health care plans may have some employers thinking their prayers have been answered. Under the Affordable Care Act, those who don’t offer health insurance coverage to...more

Medicare Star Ratings – What Plan Sponsors Need to Know By Theresa C. Carnegie and Roy M. Albert

Originally published in BNA’s Medicare Report, 11/30/2012. On Oct. 12, the Centers for Medicare & Medicaid Services published its 2013 Medicare Health Plan Quality and Performance Ratings, also called ‘‘Star Ratings’’...more

12/3/2012  /  Affordable Care Act , CMS , Medicare
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