Plan sponsors should review wellness programs for compliance with recently issued final rules, which among other things increase the maximum permissible award for certain wellness programs. On May 29, the Internal Revenue...more
The Affordable Care Act (the ACA) established the Patient-Centered Outcomes Research Institute (the Institute) in order to provide comparative clinical effectiveness research data so that patients, health care providers,...more
The Centers for Medicare & Medicaid Service’s release of the final Medicare medical loss ratio regulations allows Medicare Advantage Organizations and Part D Plan Sponsors to evaluate their operations in order to come into...more
Employers who sponsor health plans for their employees can purchase insurance contracts to fund those plans. Alternatively, employers can self-fund or self-insure those benefits, agreeing to pay the claims themselves....more
OIG continues its aggressive interpretation of scope and effect of exclusion from participation in Federal health care programs and clarifies several open questions....more
Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more
When a health plan/HMO ("Plan") provides group health coverage to employers, including the federal government, the hospitals that treat federal employees under a contract with the Plan are government "subcontractors" subject...more
The Departments of Labor, Treasury, and Health & Human Services have issued new guidance on the content requirements for health plan summaries of benefits and coverage (“SBCs”). Plan sponsors should ensure that the SBCs...more
Plan sponsors, particularly those that sponsor self-funded health plans, should review plan document provisions in light of the recent decision of the Supreme Court of the United States in US Airways, Inc. v. McCutchen. In...more
In a prior blog, I discussed the importance of including unambiguous reimbursement rights in health plan documents in order to manage healthcare costs. The enforceability of such rights was confirmed by the United States...more
On April 16, 2013, the U.S. Supreme Court issued its opinion in U.S. Airways, Inc. v. McCutchen finding in favor of U.S. Airways in its quest to recover $66,866 in medical expenses incurred by its employee as a result of a...more
Although it has not been well publicized, a significant new fee on sponsors of group health plans is scheduled to go into effect in 2014 under the Patient Protection and Affordable Care Act (“Affordable Care Act”). Earlier...more
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