As we reported in our QuickStudy on February 13, 2020, CMS filed and made available for public inspection on February 5, 2020, a new proposed rule (the “Proposed Reinsurance Rule”) under the authority of Section 1855(b)(1) of...more
As explained in our February 13, 2020 QuickStudy, CMS has proposed a new excess of loss and quota share reinsurance rule. Although it is a welcome development there are significant ambiguities in the proposed rule that we...more
The Proposed New Reinsurance Rule -
Readers of our prior QuickStudies on this topic are aware that since 2017, the long-standing use of quota share reinsurance by Medicare Advantage Organizations (“MAOs”) with respect to...more
As we previously reported in our Quick Study dated April 4, 2017, CMS, on April 3, 2017, announced that it had reconsidered its position that quota share reinsurance arrangements are not a statutorily permitted form of...more
We previously reported on February 13, 2017 that the Centers for Medicare & Medicaid Services (CMS), on February 1, 2017, in connection with its 2018 Advance Notice (Notice), advised that quota share reinsurance arrangements...more
On February 1, 2017, the Centers for Medicare & Medicaid Services (CMS), in connection with its 2018 Advance Notice (the Notice), advised that quota share reinsurance arrangements are not a statutorily permitted form of...more
Locke Lord lawyers Jon Biasetti, Baird Allis and Benjamin Sykes provide a detailed look at recent efforts by hospitals, physician practice groups and health insurance and managed care companies to lower health care delivery...more