On May 8, 2013, the OIG issued an update that supersedes and replaces its 1999 Special Advisory Bulletin, The Effect of Exclusion from Participation in Federal Health Care Programs. The updated bulletin continues to stress...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
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
In this presentation: - Policy - The Drivers of Health Care Reform? - The Exchange & Congressional Intent - Two Kinds of “Public” Exchanges - What Should You Know About the “Public”...more
Having cleared the hurdles of a Supreme Court decision and the 2010 and 2012 national elections, health care reform mandated by the Patient Protection and Affordable Care Act (“PPACA” or the “Act”) is closing in fast on key...more
The Illinois Department of Healthcare and Family Services ("Department"), Office of Inspector General ("OIG"), has now issued an Informational Notice and Voluntary Provider Self-Disclosure Protocol ("Protocol") providing...more
Recognizing that expatriate group health plans may find it impossible, or nearly impossible, to comply with all of the relevant provisions of the Patient Protection and Affordable Care Act of 2010 (PPACA), the U.S. Labor...more
A burgeoning problem is developing for out of-network healthcare providers that systemically fail to collect deductibles and coinsurance from patients. Insurance companies often seek to deny insurance coverage to subscribers...more
In early January, the Internal Revenue Service published proposed regulations on “Shared Responsibility for Employers Regarding Health Coverage.” These regulations incorporate the provisions of many previous Notices with...more
The federal government faces overwhelming challenges in trying to stem the tide of fraud in the health care system. The problem is massive, and even with the increase in resources, and adoption of new tools to fight fraud,...more
Proposed regulations issued by the Internal Revenue Service on December 28, 2012 provide some relief to large employers subject to the employer-sponsored coverage mandate under health care reform. The employer mandate is...more
Last Friday, the Department of the Treasury issued proposed regulations on the employer shared responsibility provisions in section 4980H of the Internal Revenue Code, under which an employer may be subject to an assessment...more
As the end of 2012 approaches, we consider what a notable year it has been for the future of healthcare reform, starting with the United States Supreme Court’s decision to uphold key provisions of the Patient Protection and...more
On November 19, 2012, a bill (A3444) was introduced in response to reports in the New Jersey Star Ledger that a bank purportedly provided unequal levels of health coverage to its male and female employees. The bill attempts...more
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