News & Analysis as of

Quirky Question #247, An Update on Wellness Programs

Question: Our company has been considering implementing financial incentives for employees to participate in biometric screening as part of an employee wellness program. Are there legal issues we should be...more

OIG Approves Yet Another Medigap Policy Contract with Preferred Hospital Network

On September 17, 2014, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued Advisory Opinion 14-08 [PDF]. This opinion is yet another favorable advisory opinion approving a Medicare...more

OIG Proposes Rules on Free Transportation, Hospital Gainsharing, and Other Access to Care Arrangements

The proposed rule to give providers more protections to promote beneficiary access to care solicits significant industry input. On October 2, the Department of Health and Human Services (HHS) Office of Inspector...more

Monthly Benefits Update - July 2014

Two federal appeals courts issued contradictory rulings on the validity of subsidies for the purchase of health insurance under the federal marketplace established pursuant to the Affordable Care Act (ACA). On July 22, a...more

Roadmap to Compliance: Navigating the Employer Shared Responsibility Rules

Earlier this month, the IRS issued proposed regulations that provide much-needed guidance on the new “pay or play” rules (also called the shared responsibility rules) that will apply to employers’ group health plans beginning...more

Proposed Regulations Issued on Employer Shared Responsibility Payments under the Affordable Care Act

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

Hurry Up and Wait—New Waiting Period Guidance for Health Plans

The government recently issued Notice 2012-59 (August 31, 2012), describing the 90-day limit for waiting periods to enter group health plans, as added by the Affordable Care Act (ACA). This notice provides temporary guidance...more

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