News & Analysis as of September 21, 2024

Patient Protection and Affordable Care Act (PPACA) › Co-payments

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The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal... more +

HHS Announces Temporary Copay Accumulator Non-Enforcement Policy

Ballard Spahr LLP on 12/11/2023

The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....more

HHS Court Filings Indicate that Agency Intends to Preserve Copay Accumulators

Mintz - Health Care Viewpoints on 12/5/2023

As we wrote about in our prior blog post, on September 29, 2023, John D. Bates of the U.S. District Court for the District of Columbia struck down a federal rule that permitted health plans and pharmacy benefit managers...more

Prescription for Chaos: Copay Accumulator Programs Called Into Question

Ballard Spahr LLP on 10/18/2023

Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more

Democratic AGs Ask CDC to Help Ensure Access to No-Cost HIV Prevention Drugs

Cozen O'Connor on 3/10/2023

A group of 22 Democratic AGs submitted a letter to the CDC and the National Center for Health Statistics (NCHS) urging the agencies to ensure patients are not improperly charged copays for HIV prevention services by creating...more

Updates in Co-Pay Assistance and Accumulators Legal Developments

Akin Gump Strauss Hauer & Feld LLP on 10/17/2022

Key Points - Patient advocacy groups have filed suit challenging the legality of the 2020 HHS Final Rule permitting co-pay accumulator adjustment programs. The Second Circuit has upheld HHS’ prohibition of co-pay...more

2020 Drug Coupon Rule Dropped Due to Implementation Concerns

Ogletree, Deakins, Nash, Smoak & Stewart,... on 8/28/2019

Employer plans will still be able to exclude the value of drug manufacturer coupons from annual out-of-pocket maximums, even when no generic equivalent is available, under new guidance from the Department of Labor, Department...more

At Long Last, OIG Issues Final Rule for Beneficiary Inducement Safe Harbors

Mintz - Health Care Viewpoints on 12/12/2016

More than two years since issuing the proposed rule, the HHS Office of the Inspector General (OIG) issued the long-awaited and highly anticipated final rule (the Final Rule) that provides amendments to the Anti-Kickback...more

Manatt on Health Reform: Weekly Highlights - October 2015 #3

Manatt, Phelps & Phillips, LLP on 10/21/2015

Arizona seeks Medicaid Waiver to implement new coverage restrictions for Medicaid expansion enrollees and delivery system reform; Tennessee’s uninsured rate continues to drop; and Louisiana gubernatorial candidates line up...more

Kmart Settlement Shows Breadth of Healthcare Practices Government Says Violate False Claims Act

Saul Ewing Arnstein & Lehr LLP on 9/30/2015

A recent settlement by retailer Kmart Corp. illustrates the breadth of practices in the healthcare space that the government considers to be illegal kickbacks that violate the False Claims Act (FCA). The U.S. Department of...more

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Patient Protection and Affordable Care Act (PPACA) › Co-payments

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