News & Analysis as of

Patient Protection and Affordable Care Act (PPACA) Healthcare Safe Harbors

The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal... more +
The Patient Protection and Affordable Care Act (PPAC), also known as Obamacare, is a United States federal statute passed in March of 2010. The Act creates a nationwide insurance system and provides federal subsidies to reduce the number of uninsured citizens. less -
Hogan Lovells

HHS OIG Finalizes New Exclusion Rules as Administration Exits

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With just a week left before a new administration takes office, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) finalized changes to the regulations authorizing OIG to exclude...more

Akerman LLP - Health Law Rx

The AHA’s Letter to Santa Claus

The American Hospital Association, after having been “nice” all year, penned its letter to Santa Claus with its wish list for Christmas. Its four page letter (actually addressed to President-Elect Donald Trump at 1717...more

McDermott Will & Emery

OIG Revises Safe Harbors under the Anti-Kickback Statute and Civil Monetary Penalty Rules Regarding Beneficiary Inducements

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On December 7, 2016, the Office of Inspector General of the US Department of Health and Human Services published a final rule containing revisions to both the federal Anti-Kickback Statute safe harbors and the beneficiary...more

Ballard Spahr LLP

Further Guidance on ACA Market Reforms

Ballard Spahr LLP on

Following up on the issuance of final regulations on various market reform provisions under the Affordable Care Act (ACA), the IRS has issued a notice with Questions and Answers that take a more detailed look at specific ACA...more

Mintz - Health Care Viewpoints

Skeletons in the Closet? Beware of Potential Enforcement Actions

With Halloween looming, a discussion of skeletons that may be lurking in a health care provider’s closet is timely. Many of our previous posts, as well as the monthly Qui Tam Updates published by our Health Care Enforcement...more

Saul Ewing Arnstein & Lehr LLP

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

BakerHostetler

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

BakerHostetler on

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

McDermott Will & Emery

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

McDermott Will & Emery on

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

Morgan Lewis

OIG Proposes Rules on Free Transportation, Hospital Gainsharing, and Other Access to Care Arrangements

Morgan Lewis on

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

Franczek P.C.

Monthly Benefits Update - July 2014

Franczek P.C. on

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

Bond Schoeneck & King PLLC

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

McDermott Will & Emery

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

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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

Franczek P.C.

Monthly Benefits Update - November 2013

Franczek P.C. on

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

Baker Donelson

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

Baker Donelson on

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

Ervin Cohen & Jessup LLP

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

Littler

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

Littler on

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

Saul Ewing LLP

The Benefits Game - Playbook for Compliance with the Health Care Reform’s Pay or Play Rules for Employers

Saul Ewing LLP on

The Affordable Care Act’s (ACA’s) employer shared responsibility provisions (commonly called “pay or play”) impact “large” employers and go into effect in 2014. Although effective in 2014, employers must plan NOW. Advance...more

Perkins Coie

The Affordable Care Act’s “Play Or Pay” Mandate: How It Works

Perkins Coie on

The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...more

Proskauer Rose LLP

IRS Releases Proposed Regulations on the Affordable Care Act's Play or Pay Mandate

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On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more

Pillsbury Winthrop Shaw Pittman LLP

Wellness Programs: Keeping Up With the Times

On November 20, 2012, the IRS, DOL and HHS jointly issued proposed regulations under the Affordable Care Act building on existing HIPAA regulations of wellness programs. The new proposed regulations provide clearer guidance...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Helpful Guidance Issued on Employer Mandate Issues

Notice 2012-58 (August 31, 2012) describes a number of safe harbors related to the employer mandate under the Affordable Care Act. In today’s post, I want to focus on the Notice’s safe harbor method for determining the...more

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