News & Analysis as of

Out-of-Pocket Expenses

Manatt, Phelps & Phillips, LLP

Maryland PDAB Releases Draft Upper Payment Limit Action Plan

On August 9, Maryland’s Prescription Drug Affordability Board (PDAB) released its draft action plan for establishing upper payment limits (UPLs) for drugs identified as causing or likely to cause affordability challenges. The...more

Wiley Rein LLP

CMS Releases Final Part Two Guidance on the Medicare Prescription Payment Plan: What’s Changed for Part D Plans?

Wiley Rein LLP on

The Centers for Medicare & Medicaid Services (CMS) updated its guidance on the Inflation Reduction Act of 2022’s (P.L. 117-169) (IRA) Medicare Prescription Payment Plan (M3P) with its release of the Final Part Two Guidance on...more

Whiteford

CMS Releases Final Part Two Guidance of the Medicare Prescription Drug Payment Plan

Whiteford on

The Department of Health and Human Services (HHS), in conjunction with the Centers for Medicare and Medicaid Services (CMS), is striving to alleviate the financial strain of medication costs on the elderly and disabled...more

Mintz - Health Care Viewpoints

Mintz IRA Update — The Consequences and Costs of Redesigning the Part D Program

The passage of the Inflation Reduction Act of 2022 (IRA) marked a significant milestone in Congress’s ongoing efforts to address escalating health care costs. While the IRA aims to rein in government spending on Medicare and...more

Napoli Shkolnik

Pricing Algorithms Help Insurers and Harm Patients

Napoli Shkolnik on

The healthcare industry grapples with a pervasive issue of providers overcharging insurers for medical procedures performed on their patients. To combat this, insurers have turned to MultiPlan—a data analytics firm that...more

Stoel Rives - Health Law Insider®

IRS Announces HSA and HDHP Limits for 2025

The Internal Revenue Service has released Rev. Proc. 2024-25 announcing the inflation-adjusted limits for high deductible health plans (HDHPs) and health savings accounts (HSAs) in 2025.  The updated 2025 limits are as...more

Woodruff Sawyer

​​​​​IRS Releases 2025 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits

Woodruff Sawyer on

In Rev. Proc. 2024-25, the IRS released the inflation adjusted amounts for 2025 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs).  The table below summarizes those adjustments and other...more

Marshall Dennehey

What’s Hot in Workers’ Comp – Special PA Alert

Marshall Dennehey on

In Schmidt v. Schmidt, Kirifides & Rassias (WCAB), 1039 C.D. 2021, filed November 14, 2023, a case of first impression, the Pennsylvania Commonwealth Court ruled that claimants are entitled to reimbursement for out-of-pocket...more

Mintz - Health Care Viewpoints

CMS Releases Part Two of Guidance for the Inflation Reduction Act’s Medicare Prescription Payment Plan

On February 15, 2024, the Centers for Medicare and Medicaid Services (CMS) released the Medicare Prescription Payment Plan Draft Part Two Guidance (Part Two Guidance) as part of the Inflation Reduction Act’s (IRA) efforts to...more

Bass, Berry & Sims PLC

CMS & HHS Withdraw Appeal to Recent Copay Accumulator Federal District Court Decision: 2020 Accumulator Rule Still in Effect

On January 16, the Centers for Medicare & Medicaid Services (CMS) & the U.S. Department of Health and Human Services (HHS) withdrew an appeal to a recent copay accumulator court decision, HIV and Hepatitis Policy Institute et...more

Epstein Becker & Green

Medicare Advantage, Part D, and More: Proposed Rule Outlines Significant Policy and Technical Changes for CY 2025

Epstein Becker & Green on

On November 15, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule titled Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit...more

McDermott+

CMS Issues Two Health Plan Proposed Regs: Different Markets but Similar Policy Goals

McDermott+ on

Before the Thanksgiving holiday, the Centers for Medicare & Medicaid Services (CMS) issued two proposed regs that would make changes to certain health insurance plan policies starting in 2025: one impacting Medicare Advantage...more

Cornerstone Research

Potential Unintended Economic Impacts of the Inflation Reduction Act on the Pharmaceutical Industry

Cornerstone Research on

The Inflation Reduction Act (IRA) was signed into law in August 2022 with the goal of curbing inflation by, among other things, lowering prescription drug prices. Notable prescription drug provisions of the IRA include the...more

Ballard Spahr LLP

Prescription for Chaos: Copay Accumulator Programs Called Into Question

Ballard Spahr LLP on

Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more

McDermott+

New No Surprises Act Announcements Indicate Bumpy Road Ahead

McDermott+ on

The bumpy road toward implementing the No Surprises Act took another turn last Friday, October 6, 2023. The US Departments of Health and Human Services (HHS), Labor and the Treasury (collectively, the Departments) provided...more

Mintz - Health Care Viewpoints

Court Strikes Down HHS Rule on Copay Accumulators: Implications for Health Plans and PBMs

In a significant development with far-reaching implications for health plans and pharmacy benefit managers (PBMs), Judge John D. Bates of the U.S. District Court for the District of Columbia has recently struck down a federal...more

Goodwin

Federal Court Strikes Down Copay Accumulator Programs

Goodwin on

On September 29, 2023, the U.S. District Court for the District of Columbia vacated a Trump-era rule from 2021 that allowed insurers to exclude drug manufacturer co-pay support coupons and assistance from a patient’s annual...more

Akerman LLP - Health Law Rx

THE NO SURPRISES ACT: Hoping for an End to the Surprises

By looking at the events that have transpired since the Consolidated Appropriations Act, 2021, which includes the No Surprises Act (the Act), was signed into law, it is clear that the Departments of Health and Human Services,...more

Mintz - Health Care Viewpoints

Mintz IRA Update — Other Key IRA Programs and Developments: The Medicare Prescription Drug Inflation Rebate Program and Maximum...

Although most of the recent focus around the implementation of the Inflation Reduction Act (“IRA”) by the press and industry stakeholders has been on the Medicare Drug Price Negotiation Program, the IRA has several other...more

Bass, Berry & Sims PLC

Court Strikes Down Federal Surprise Billing QPA Calculation Rules, Continuing Pause on Arbitrations

Bass, Berry & Sims PLC on

On August 24, the U.S. District Court for the Eastern District of Texas once again struck down parts of the regulations governing the arbitration process created by the No Surprises Act (NSA) to settle payment disputes...more

Epstein Becker & Green

Texas Federal Court Issues Fourth Ruling Invalidating Parts of the Administration’s No Surprises Act Regulations

Epstein Becker & Green on

On August 24, 2023, the U.S. District Court for the Eastern District of Texas issued an opinion and order in Texas Medical Association, et al. v. United States Department of Health and Human Services(“HHS”)(“TMA III”). TMA...more

Davis Wright Tremaine LLP

New FAQs Address No Surprises Act Impact on ACA Maximum Out-of-Pocket Limits and Facility Fee Transparency

Employers should be aware that the No Surprises Act has an impact on the maximum-out-of-pocket ("MOOP") limit for annual cost-sharing under the Affordable Care Act ("ACA") and facility fee transparency. The new set of...more

Snell & Wilmer

CMS' Transparency-in-Coverage Rule: One Year Later

Snell & Wilmer on

In October 2020, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Transparency in Coverage Rule (“the Rule”), requiring most health insurance plans and issuers offering individual or group coverage to...more

Proskauer - Law and the Workplace

Do We Have to Pay for That?  Part 3—Employee Expenses

In this blog series, we look at a variety of activities and items and discuss whether an employer has an obligation to pay for them (or the time employees spend in them). In our first installment of this series, we looked at...more

King & Spalding

First Annual Report on the No Surprises Act’s Impact on the Health Care Market is Released

King & Spalding on

On July 6, 2023, the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) released the first of five required annual reports on the impact of the No Surprises Act (NSA) on health care markets (the Report)....more

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