As you may know the Affordable Care Act imposed a new fee on issuers of individual and group health insurance policies and plan sponsors of self-funded plans. As previously noted in our blog, on December 5, 2012, the Internal...more
Earlier this week the IRS released the updated Form 720 which plan sponsors and third party administrators must utilize when reporting the Patient Centered Outcome Research Fee....more
On May 2, 2013, CMS released a proposed rule [PDF] for the Inpatient Rehabilitation Facility Prospective Payment System for fiscal year (FY) 2014. The proposed rule sets forth Medicare payment policies and rates governing...more
The IRS has released its proposed regulations [PDF] detailing the requirements for conducting and reporting Community Health Needs Assessments (CHNAs) under section 501(r)(3) of the Internal Revenue Code, which were...more
In a case closely monitored by the healthcare industry, a recent decision from the United States District Court for the District of Columbia expanded the jurisdiction of the Office of Federal Contract Compliance Programs...more
On April 5, 2013, the Internal Revenue Service published proposed regulations (Proposed Regulations) in the Federal Register that provide guidance to charitable hospital organizations on the community health needs assessment...more
The Health Resources and Services Administration (“HRSA”) has issued a final rule (“HRSA Rule”) that will eliminate duplicative federal reporting requirements of provider sanctions and other adverse actions taken against...more
Health Care Reform: Agencies Issue Proposed Regulations on 90-Day Waiting Period Limitation - On March 21, the IRS, DOL, and Department of Health and Human Services issued proposed regulations on the 90-day waiting...more
Originally Published in BNA Bloomberg, Medical Devices Law & Industry Report on March 20, 2013. On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited final regulations for...more
After years of deliberation, the Center for Medicare & Medicaid Services (CMS) published its long-awaited regulations to implement the specific requirements of the Physician Payment Sunshine Act (Sunshine) on February 1,...more
In This Alert: - A. What Is The Employer Shared Responsibility Penalty? - What Is The “Failure To Offer Coverage Penalty”? - How Is The “Failure To Offer Coverage Penalty” Calculated? - What Is...more
The Internal Revenue Service (IRS) has released proposed regulations on the health insurer fee under section 9010 of the Patient Protection and Affordable Care Act (PPACA). The regulations, which were published in the Federal...more
The Centers for Medicare and Medicaid Services (CMS) issued the final regulations on the U.S. Sunshine Act on February 8, 2013. Transparency Reports and Reporting of Physician Ownership or Investment Interests, 78 Fed. Reg....more
The Department of Labor ("DOL") recently released a series of final rules affecting health benefits provided through multiple employer welfare arrangements ("MEWAs"). Notably, the 2012 Form M-1 filing deadline has been...more
On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) published long-awaited rules (the "Rules") detailing manufacturers' and group purchasing organizations' reporting requirements under Section 6002 of the...more
In This Issue: - Healthcare Provisions in the American Taxpayer Relief Act - the Good, the Bad and the Ugly - American Taxpayer Relief Act Amends Overpayment Recovery Time Limits - OIG Advisory Opinion Sheds...more
With the re-election of President Obama and the Supreme Court's recent decision upholding portions of the Affordable Care Act (the "ACA"), health care reform is here to stay for the foreseeable future. Though limited...more
As everyone knows, the Patient Protection and Affordable Care Act was upheld in a somewhat surprising Supreme Court decision last month. (For a recap of the decision see our Legal Alert on the case). Set out below is a...more
Now that the Supreme Court has upheld the constitutionality of the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act (collectively, the “Act”), employers must move...more
The Patient Protection and Affordable Care Act (the “Act”) requires employers to report the cost of coverage under an employer-sponsored group health or medical plan. This requirement was optional for all employers in 2011....more
Centers for Medicare & Medicaid Services (CMS) issued on December 14, 2011 its much-anticipated proposed rule interpreting the requirements of the Physician Payment Sunshine Act (Act), enacted by Congress as Section 6002...more
On January 3, 2012, the Internal Revenue Service ("IRS") released Notice 2012-9, which restates and clarifies its prior guidance on the requirement under the Affordable Care Act to report the cost of employer-sponsored health...more
Bright-Light Scrutiny on Payments by Drug and Device Makers to Physicians and Teaching Hospitals and Certain Physician Ownership Interests The Centers for Medicare and Medicaid Services (CMS) published in the Federal...more
The Physician Payments Sunshine Act (Sunshine Act), passed on March 23, 2010, requires all U.S. manufacturers of drugs, medical devices, biologics, and medical supplies covered under Medicare, Medicaid, or the State...more
On March 29, 2011, the Internal Revenue Service (“IRS”) released Notice 2011-28, which provides guidance to employers on the requirement under the Affordable Care Act (the “Act”) to report the cost of employer-sponsored...more
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