Cost-Sharing

News & Analysis as of

What Employers Need to Know About Employer Payment Plans

Some employers may have offered employees pre-tax dollars to help purchase insurance. Such arrangements are called Employer Payment Plans. Now, however, Employer Payment Plans are prohibited under the Affordable Care Act...more

Highlights of OIG's Proposal to Amend Safe Harbors to the Antikickback Statute and CMP Rules, and to Add New Safe Harbors

On October 3, 2014, the Department of Health and Human Services Office of Inspector General (OIG) issued a proposed rule to establish new safe harbors under the antikickback statute and the civil monetary penalty (CMP) rules,...more

HHS Office of Inspector General Proposes Expansions of Anti-Kickback Safe Harbors and Civil Monetary Penalties Law Exceptions

On October 3, 2014, the Office of the Inspector General (the “OIG”) of the U.S. Department of Health and Human Services (“HHS”) issued a proposed rule that would amend regulations implementing the federal anti-kickback...more

Proposed Rule Issued by OIG Realigns Its Enforcement Views with Health Care Reform Goals

Fridays never seem to be slow in the health care regulatory world. On Friday, October 3rd, the HHS Office of the Inspector General (OIG) issued a highly anticipated proposed rule (the Proposed Rule) that provides amendments...more

OIG Releases Proposed Rule Adding New Safe Harbors to the Anti-Kickback Statute

Last week, the HHS OIG released a proposed rule published in the October 3 Federal Register that would add new safe harbors to the Anti-Kickback Statute and expand the list of conduct exempt from civil monetary penalties...more

OIG Proposes Expanding Anti-Kickback Statute Safe Harbors and Revising Civil Monetary Penalty Regulations

On October 2, 2014, the Office of Inspector General of the U.S. Department of Health and Human Services (OIG) published a proposed rule containing revisions to both the Anti-Kickback Statute (AKS) safe harbors and the civil...more

Sometimes the Government is Here to Help: OIG Proposes More Flexibility in Rules Governing Local Transportation, Beneficiary...

The U.S. Department of Health & Human Services, Office of Inspector General ("OIG") just released a proposed rule (“Proposed Rule”) that provides long awaited guidance on patient transportation services, relaxes the...more

Pennsylvania’s final insurance holding company regulations – what PA insurers need to know for intercompany agreements

Pennsylvania insurers should be prepared to comply now with significant new requirements for intercompany agreements – management agreements, service contracts, tax allocation agreements, guarantees and cost-sharing...more

New Health Care Reform FAQs, Part II

The DOL, HHS, and IRS (the “Departments”) recently released new Health Care Reform Frequently Asked Questions (“FAQs”). The FAQs provide guidance on cost-sharing limitations and coverage of preventive services....more

New FAQs Address Effect of Affordable Care Act on COBRA and Other Matters

In a wide-ranging set of frequently asked questions (FAQs) and other guidance, the U.S. Departments of Labor, Treasury, and Health and Human Services have addressed a number of issues pertaining to the Affordable Care Act...more

The US tax rescission doctrine: when the parties want an agreement to disappear

The old saw about the best-laid plans of mice and men also goes for international tax planning and transactions with significant tax consequences. Sometimes the business and/or financial assumptions around the planning...more

Agencies Share Guidance on Cost-Sharing

Earlier this month, the Departments of Treasury, Labor and Health and Human Services (Agencies) jointly issued additional guidance on the application of the cost-sharing limitations imposed under the Affordable Care Act. It...more

New Final Regs on Use of Differential Income Stream in Evaluating Cost-Sharing Arrangements

On August 26, 2013, the United States Treasury Department issued new final regulations under Internal Revenue Code (IRC) Section 482. The new regulations provide guidance on the “income method” for determining taxable income...more

Staying the Course: HHS Finalizes the Essential Health Benefits Regulations for 2014

The U.S. Department of Health and Human Services (HHS) Essential Health Benefits Final Rule and actuarial value regulations offer few surprises and much needed certainty to enable group health plans and health insurance...more

Health Care Reform: Additional ACA Guidance on Preventative Care Coverage Released

Today federal regulators released additional guidance on the Affordable Care Act’s preventative care requirements for non-grandfathered plans, including additional information on contraceptive coverage. ...more

IRS Issues Proposed Regulations for Employer-Shared Responsibility under ACA

On December 28, 2012, the IRS issued proposed regulations with respect to employer-shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). Employers are permitted to rely on these proposed...more

CMS Proposes Rule to Increase Medicaid Cost-Sharing

On January 22, 2013, CMS published a proposed rule in the Federal Register that would allow states to increase cost-sharing for Medicaid beneficiaries. Specifically, for individuals with incomes below 100% of the federal...more

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