On the heels of the United States Supreme Court’s recent holding in U.S. Airways v. McCutchen, where the Court held that a group health plan’s reimbursement rights are not automatically subject to equitable defenses, it...more
Clearing up the Rumors around Health Reform Delays: What Really Happened, What Won’t and Steps Employers and Insurers Can Take Now - Rumors are flying in health policy circles that the Obama Administration might delay...more
For better or worse, the ACA or Health Care Reform is still with us. If you do not want to end up in the penalty box in 2014, you must know whether you are subject to the employer shared responsibility provisions of the ACA...more
You may have woken up today to media reports of large employers exploring the idea of dropping traditional health plans in favor of very limited health care plans as a way to lessen the burden imposed on large employers for...more
A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more
On May 8, 2013, the Department of Labor (DOL) issued long-awaited temporary guidance and a model notice to be provided to employees about upcoming coverage options through the health care exchange, known as the Marketplace,...more
Employers have until October 1, 2013, to provide notice to current employees of coverage options available through the Health Insurance Marketplace established under the Affordable Care Act. On May 8, 2013, the U.S....more
In This Presentation: •Welcome •Overview of the Employer Shared Responsibility Rules - Impact on Corporate Structure - Time Line Examples to Demonstrate Application of Measurement, Administrative & Stability...more
Come 2014, the Health Insurance Exchanges will provide another option to COBRA “qualified beneficiaries” who are considering whether to elect to continue health coverage under an employer’s group plan....more
The IRS recently released new proposed regulations to implement the Shared Responsibility or “Play or Pay” provisions of Health Care Reform. The proposed regulations provide a wealth of detail on key issues required to...more
The U.S. Department of Labor (DOL) has published guidance on the notice that most employers must provide to their employees by October 1, 2013, about the insurance that will be available through health care marketplaces known...more
The U.S. Department of the Treasury has published proposed regulations that provide guidance on how an employer may determine whether its group health plan provides “minimum value.”...more
Starting in 2014, provisions of the Patient Protection and Affordable Care Act become effective known as “Pay or Play” or “Employer Shared Responsibility.” Large employers will be faced with the decision whether to offer...more
Last week the Centers for Medicare & Medicaid Services (CMS) issued new proposed regulations on FY 2014 payment updates and regulatory policy changes for inpatient and long term care hospitals, skilled nursing facilitates,...more
Last Friday the IRS released additional proposed regulations implementing the minimum value requirement for coverage sponsored by employers with 50 or more FTEs. The proposed rules provide that amounts contributed by...more
Under the Patient Protection and Affordable Care Act (the “Act”), the federal government, state governments, insurers, employers, and individuals all share responsibility to make affordable health insurance coverage widely...more
Probably the most important mandate for employers is the “play or pay” mandate, also known as the employer-shared responsibility, which will require large employers (those with the equivalent of 50 or more full-time...more
A federal district court has confirmed the position of the Office of Federal Contract Compliance Programs (OFCCP) finding that three hospitals providing medical services to U.S. government employees, and receiving payments...more
The US Departments of Labor, Health and Human Services (HHS), and the Treasury (the “Agencies”) jointly issued yesterday a document entitled “FAQs about the Affordable Care Act Implementation Part XV” (“FAQs”) addressing four...more
Will Employers Face a Surge in Enrollment? Employers start by asking one big question. Are they currently excluding a significant number of employees to whom they now will need to offer coverage? For many, the answer...more
The U.S. Department of Labor has issued a set of frequently asked questions, together with a new template, for the Summary of Benefits and Coverage (SBC) that applies to group health plans and individual health insurance. The...more
The U.S. Supreme Court has ruled that the clear terms of an employer's group health plan override an employee's equitable defenses in determining the plan's right to recover amounts from a third party. This decision points...more
In This Issue: The ACA’s Effects on the Employer Insurance Market; Using the Premium Assistance Option to Purchase Coverage for Medicaid Beneficiaries in the Exchange: A Review of the Legal, Policy and Operational Issues; and...more
On July 31, 2013, the first of various fees will be due that are imposed by the Affordable Care Act on self-insured group health plans and/or issuers of insured health policies providing accident and health coverage. Beyond...more
Starting in 2014, federal law will prohibit group health plans from imposing eligibility waiting periods longer than 90 days. Recently, federal regulators published proposed regulations designed to implement this limitation....more
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