Despite Issuance of Final Rule on Price Transparency, Are Health Care Rates Too Complicated to Be “Consumer Friendly”?

Epstein Becker & Green
Contact

Epstein Becker & Green

The Centers for Medicare & Medicaid Services (“CMS”) recently issued a final rule requiring hospitals to publicly disclose their rates, including negotiated rates with third-party payors regardless of product line, by January 1, 2021 (“Final Rule”).[1] The Final Rule’s intent is to increase price transparency so that health care consumers can “shop” for health care services. The Final Rule does not exclude any particular type of health plan, product, or line of business, except for rates that are not negotiated (e.g., fee-for-service Medicare or Medicaid). 

Hospitals that are deemed non-compliant are subject to fines of up to $300 per day, up to a maximum of $109,500 per year. 

The Final Rule has been subject to pushback from hospitals. Most notably, on December 4, 2019, the American Hospital Association, joined by other industry groups, filed a lawsuit against CMS in federal court over the Final Rule. The plaintiffs assert that the Final Rule exceeds the scope of the Patient Protection and Affordable Care Act, which provides the basis for the rule, and violates the First Amendment by compelling speech, among other reasons.

This Client Alert will address the overall scope of the Final Rule and illustrate the challenge of making a hospital’s negotiated rates “consumer friendly” for individuals shopping for health care services.

There is a similar, but proposed, rule regarding price transparency requirements that would be applicable to payors (including self-funded plans and insurers), which will be the subject of a separate Client Alert.

Scope of the Final Rule

The Final Rule applies to any facility that is licensed or approved to operate as a hospital pursuant to a state’s licensing law, irrespective of Medicare enrollment status or designation. Hospitals that operate under a single license as part of a health system must each separately disclose negotiated rates with third-party payors, and otherwise comply with the Final Rule’s requirements. Further, the definition of “hospital” under the Final Rule includes critical access hospitals, inpatient psychiatric facilities, sole community hospitals, and inpatient rehabilitation facilities, and excludes ambulatory surgical centers or other “non-hospital” sites of care. 

A hospital must disclose prices for all items and services—including bundled services or “service packages”—that the hospital may provide to patients under either an inpatient or outpatient classification and for which the hospital has established a standard charge.  Examples of these items and services include, but are not limited to, supplies, procedures, room and board, use of the facility fees, employed professional charges, and any other items or services for which a hospital has established a charge. Because bundled services are included within the definition of “items and services,” hospitals must also provide inpatient case rates or diagnosis related group (“DRG”) pricing information.

Specifically, the Final Rule requires a hospital to disclose in a machine-readable format any rates that (1) are gross (i.e., chargemaster) charges; (2) the hospital has negotiated with “an entity that, by statute, contract, or agreement, is legally responsible for payment of a claim for a health care item or service; (3) are discounted cash prices, or “self-pay” prices; and (4) are its de-identified minimum and maximum negotiated charges, or its lowest and highest negotiated rates for all items or services, regardless of payor.

Besides the disclosure of rates in a machine-readable format, hospitals are required to determine 230 “shoppable”[2] services, in addition to the 70 CMS-identified shoppable services, and make publicly available a list of their payor-specific negotiated charges for each of those shoppable services in a “consumer friendly” manner. The list of 70 mandated services includes evaluation and management, medical/surgical, laboratory, and radiology services.

Using the Disclosed Rates to Make Health Care Decisions

To demonstrate how the Final Rule would impact both hospitals and consumers when making health care decisions, the following example walks through how a potential patient could make use of the data required by the Final Rule and the limitations hospitals will have in providing reliable information.[3]

John Doe is an employee of a large corporation through which he receives health coverage, and he is in need of a knee replacement. He has been having knee trouble for years and has been receiving physical therapy and periodic non-surgical interventions, but his orthopedist now recommends that John finally get the knee replaced.

John’s orthopedist has privileges at Memorial Hospital and would like to perform the procedure there, but John wants to make sure he won’t pay too much out of pocket for the procedure and decides to price the procedure at home before deciding where he will have it done (and by whom).

John has never put much thought into his insurance; he’s always gone to in-network providers, and has paid what always seemed like a reasonable copay when he went. As a threshold issue, if John is a savvy consumer, he may realize that he has a relatively small copay or coinsurance with a low deductible with his plan and that as long as he goes to an in-network hospital, he will not have to pay more than his copay and deductible. His analysis may then be as simple as checking to see whether Memorial Hospital is in-network,[4] and, if it is, he may have no use for the price transparency data. This does not, of course, take into account “surprise bill” issues created by out-of-network professionals providing services at Memorial Hospital, or other similar issues, but the price transparency data likely would not address that issue, either. Plus, John may also know that his state has a relatively robust surprise bill law, so he’s not likely to have to pay more than his deductible at an in-network hospital and simply end his inquiry there. 

But let us assume that John knows that he has a high-deductible plan that will impose a greater financial burden on him. So, he goes home and checks his insurance card, and sees that he has insurance from State General Health Insurance, and his insurance card has a “PPO” stamp on it. He goes to Memorial Hospital’s consumer-friendly shoppable services pricer tool, and first notices that “State General Health Insurance” is broken into many different companies with a variety of names, such as “Group Health, Inc.,” “AmeriHealthGroup,” and “HealthCorp.” John isn’t sure which one he has; he looks at his insurance information from his employer and all the brochures just say “StateGenHealthIn.” After spending an hour looking at all the literature and finding no answer, John finally calls the help line on the back of his card. While on the telephone with customer service, he finds out that his insurance is provided through HealthCorp, a subsidiary of State General Health Insurance.

John goes back to the pricer tool from Memorial Hospital and takes a look at HealthCorp. He is then presented with another question that he doesn’t know the answer to: Is his insurance fully insured or self-insured? John ends up emailing his human resources representative and finds out that his health insurance is fully insured. He goes through a similar exercise to find that his insurance is a “large group” PPO product.

With this information, John goes back to Memorial Hospital’s pricer tool, and enters that he’s looking for a full knee replacement on an inpatient basis using rates negotiated with his plan and product. The tool takes him to DRG code 470, “Major Joint Replacement of Reattachment of Lower Extremity without MCC,”[5] and finds that the rate for that DRG is $18,000. He goes through the same exercise for the other hospital in his town, and finds that DRG 470 at that hospital for his coverage is $15,000.

These rates will likely have a number of disclaimers because, in order to calculate the rate, the hospital was required to convert the rates from the All Patients Refined DRG methodology in the relevant payor agreement to a dollar amount and then make a variety of assumptions as to what the payor might do when processing a claim for such service based on the terms of the agreement. Such agreement might include the following common adjustments:

  • “lesser of” language (comparing chargemaster rates to negotiated rates and paying the lesser of both);
  • downgrades to a different DRG code;
  • application of “site of service” adjustments, bundling, and other payor payment policies;
  • pass-through costs (including, but not limited to, the cost of the replacement joint “implant”);
  • carved-out services payable by a separate vendor contracted with the payor (as negotiated by patient’s insurer, which may include radiology, laboratory, or other services);[6]
  • services billed by professionals not employed by the hospital (including, but not limited to, anesthesia);
  • additional services that the patient’s surgical and care team may deem appropriate or necessary in the course of the procedure and recovery that are not included in the DRG code referenced above; and
  • any downgrades or denials of payment because the patient and/or hospital did not notify payor of service in advance or obtain prior authorization for the service or the applicable payor determined that the service was not medically necessary.[7]

In addition, Memorial Hospital could run into more substantial issues in disclosing rates for such DRG if it participates in a bundled payment arrangement for a joint replacement “episode” whereby the overall rate is much higher, but the bundle covers services outside of the DRG code, such as 90 days of services both before and after the actual joint replacement surgery. (For other services, the pricer tool might simply state “n/a” because the hospital is reimbursed on a capitated basis for all service provided to that particular patient population.[8])

John isn’t quite sure what to make of all these disclaimers, other than that his knee replacement isn’t going to cost what the pricer tool says it will—but he’s not sure what it will cost in the end.

Knowing these estimated rates, John then has to return to his benefit plan to understand what he has to pay out of pocket. He hasn’t had any major medical expenses before this procedure, so he’s unfamiliar with his deductible and the distinction between copayments and coinsurance. He does a little research and understands that inpatient hospital procedures have a 20 percent coinsurance obligation (he also goes back to check that the knee replacement is inpatient), and he has a $5,000 deductible. He has to check how much of his deductible he’s used, and sees that it’s very little—and he’s not going to exceed it at either hospital with the quoted rates. So, then John does the math to see his obligation at Memorial Hospital will be $3,600, and only $3,000 at the other hospital—but he knows both amounts are subject to many disclaimers.

After this exercise, John is ready to choose where he wants his knee replacement done. He must also consider in all of this whether his orthopedist has privileges at the other hospital, and, if not, whether saving $600 is worth both finding a different orthopedist who has such privileges and having the procedure performed by a physician other than the one who has been treating him since his knee pain began.

Conclusion

The example above is offered to provide a glimpse into the complexity of health care pricing and reimbursement. The example also demonstrates that even complete rate transparency by hospitals may not be enough to affect a health care consumer’s spending practices because (1) the issue is too complicated to generate a reliable cost estimate for the patient; (2) even if such an estimate could be generated, obtaining and understanding it may be too burdensome for consumers; and (3) it’s too difficult to estimate the value that a consumer places on continuing his or her care with his or her physician and reliance on his or her physician’s medical advice. There are many hurdles that hospitals must overcome to meaningfully comply with the Final Rule, and it is questionable if they will even be able to provide useful data to consumers. And even if they are able to, it is questionable whether consumers will be able to make effective use of the data. Our current health care system may be too complex for price transparency to effectively achieve its intended goals. 

ENDNOTES

[2] “Shoppable” means elective services or those planned in advance.

[3] There are other potential implications of the data disclosed pursuant to the Final Rule, most notably in the negotiation of rates between hospitals and payors; those implications may be the subject of future Client Alerts.

[4] Note that plans often rent their networks to other entities and that hospitals do not always know if a particular rate applies to such entities. So, knowing if a particular hospital is “in-network” is not always straightforward.

[5] This does not address a potential adjustment based on acuity, nor does it, as explained later in this section, account for potential services outside the DRG code. Further, while a knee replacement is a fairly simple example because there are limited potentially applicable DRGs, it is unclear how this example would work with a procedure or illness that has the potential to implicate multiple DRGs that cannot be determined in advance. For example, someone who may be shopping for his or her cancer treatment may not know whether or not the applicable hospital may determine to perform a surgical intervention.

[6] Hospitals will not be able to determine the costs of services that are explicitly carved out of their participation agreements with payors.

[7] There are various other factors that may affect the rate that are not relevant to the consumer but may be of concern to the hospital. A hospital may, for example, accept a lower rate but have the ability to earn more pursuant to a shared savings or shared risk arrangement applicable to the service. While this would not affect the patient, it would be relevant to hospitals and payors analyzing the data.

[8] The Final Rule also does not address whether an intermediary entity that contracts with payors on a capitated basis on behalf of a hospital (e.g., an accountable care organization or an independent practice association) is itself a “payor” for which the hospital would also be required to disclose rate data; such information would, presumably, be of little use in achieving the Final Rule’s intended purposes, as neither payors, other hospitals, nor consumers would find much use in capitation rates paid to an intermediary entity and downstream reimbursement rates that may be based more on corporate structure and cash flow than the value of care.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Epstein Becker & Green | Attorney Advertising

Written by:

Epstein Becker & Green
Contact
more
less

Epstein Becker & Green on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.