News & Analysis as of

Monthly Benefits Update - November 2014

U.S. Supreme Court Grants Review of ACA Case Involving Premium Subsidies Offered Through Federally Facilitated Exchanges - The Supreme Court granted review in King v. Burwell, a Fourth Circuit case that upheld an IRS...more

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

Don't Forget! Preparing for the Affordable Care Act Employer Mandate

With 2015 just a few weeks away, employers with 100 or more full-time and full-time equivalent employees should be gearing up for the implementation of the Affordable Care Act (“ACA”) employer mandate, which subjects...more

Health Law Alert: OIG Releases Proposed Revisions to Anti-Kickback Safe Harbors and Civil Monetary Penalty Rules

The Department of Health and Human Services Office of Inspector General (OIG) recently released a proposed rule that revises safe harbors under the Anti-Kickback Statute (AKS) and Civil Monetary Penalty (CMP) rules regarding...more

Affordable Care Act in Mergers and Acquisitions: New Guidance from Internal Revenue Service

In Notice 2014-49, the Internal Revenue Service (“Service”) issued guidance on how to avoid potential penalties under the Affordable Care Act (“ACA”) in connection with mergers and acquisitions (“M&A”). The notice provides a...more

Analysis of HHS OIG Proposed Rule to Amend the Anti-Kickback Safe Harbors, CMP Rules on Beneficiary Inducements & Gainsharing...

On October 3, 2014, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) published a major proposed rule that would amend the safe harbors to the Anti-Kickback Statute (AKS) and the Civil...more

OIG Announces Proposed AKS and CMP Regulations

On October 3, 2014, the Office of the Inspector General (“OIG”) issued a proposed rule codifying into regulation several statutory changes to the Antikickback Statute (“AKS”) and the Civil Monetary Penalty (“CMP”) Law. Nearly...more

OIG Special Advisory Bulletin Provides Guidance on Application of Federal Anti-Kickback Statute to Pharmaceutical Manufacturer...

In recent years, copayment coupon programs have become standard promotional practices for both large and small pharmaceutical manufacturers. Copayment coupons are typically offered to commercially insured patients in order to...more

OIG Proposes New Safe Harbors to the Anti-Kickback Statute and New Exceptions to the Two Civil Monetary Penalty Provisions

On October 3, 2014, the Department of Health and Human Services’ Office of Inspector General (“OIG”) published a proposed rule (“Proposed Rule”) to add new safe harbors to the federal health care program anti-kickback statute...more

Proposed Updates to the Civil Monetary Penalties Law for Health Care Providers

On October 3, 2014, the Office of Inspector General of the Department of Health and Human Services (“OIG”) published a proposed rule and request for comments (“Proposed Rule”) that would amend certain rules under the Civil...more

OIG Proposed Anti-Kickback Safe Harbors and CMP Regulations: The End of Frustration or Just the Beginning?

On October 3, 2014, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published an unexpected, yet long-awaited, set of proposed rules that would add new anti-kickback law safe harbors,...more

Highlights of OIG's Proposal to Amend Safe Harbors to the Antikickback Statute and CMP Rules, and to Add New Safe Harbors

On October 3, 2014, the Department of Health and Human Services Office of Inspector General (OIG) issued a proposed rule to establish new safe harbors under the antikickback statute and the civil monetary penalty (CMP) rules,...more

OIG Releases Proposed Rule Adding New Safe Harbors to the Anti-Kickback Statute

Last week, the HHS OIG released a proposed rule published in the October 3 Federal Register that would add new safe harbors to the Anti-Kickback Statute and expand the list of conduct exempt from civil monetary penalties...more

OIG Proposes Expanding Anti-Kickback Statute Safe Harbors and Revising Civil Monetary Penalty Regulations

On October 2, 2014, the Office of Inspector General of the U.S. Department of Health and Human Services (OIG) published a proposed rule containing revisions to both the Anti-Kickback Statute (AKS) safe harbors and the civil...more

OIG Offers Greater Protections for Health Care Providers in New Proposed Rule

On October 3, 2014, the U.S. Department of Health and Human Services of the Office of Inspector General (OIG) issued a Proposed Rule amending both the safe harbors to the anti-kickback statute and the civil monetary penalty...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

The Affordable Care Act—Countdown to Compliance for Employers, Week 37: Stalking the Elusive “Variable Hour Employee”

For “applicable large employers” (i.e., generally, those employers who employed an average of at least 50 full-time employees on business days during the preceding calendar year), determining which employees are “full-time”...more

Employee Benefits: Is Your Health Plan Premium Affordable Under The ACA?

By now, most large employers are aware that they are required to offer "affordable" health care coverage to their full-time employees beginning in 2015 in order to avoid potential penalties under the shared responsibility...more

Final ACA Shared Responsibility Regulations Released

Plan sponsors now have the final piece of the puzzle needed to finalize their 2015 pay-or-play strategies. The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently issued the highly...more

U.S. Privacy and Data Protection: 2013 Year in Review and a Look Ahead to 2014

In Boston, we celebrated Data Privacy Day (January 28) by presenting “U.S. Privacy and Data Protection: 2013 Year In Review and a Prediction of What’s to Come in 2014” for participants in an IAPP KnowledgeNet. Our panel of...more

Monthly Benefits Update - November 2013

Health & Welfare Plans - Health Care Reform: Supreme Court Grants Review to Two Cases Challenging ACA’s Contraception Coverage Mandate - The United States Supreme Court has agreed to hear two cases challenging...more

The Clock is Ticking -- October 1 Deadline Approaches for Employers to Issue Health Care Exchange Notice

U.S. Department of Labor (DOL) guidance issued under the Affordable Care Act (ACA) requires employers to provide employees with a notice regarding health care exchanges (now called "marketplaces"). ...more

IRS Issues Proposed Rules For Employer “Shared Responsibility”

With the Patient Protection and Affordable Care Act on the horizon, employers are focused on the costs associated with benefits plans and medical coverage....more

ACA Employer Play or Pay Requirements: What Does it Mean for Employers?

Beginning in 2014, the Affordable Care Act (ACA) will require “large” employers to offer their full-time employees healthcare coverage that meets certain standards or pay a penalty. Whether an employer opts to “play-or-pay”...more

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