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Health Insurance Department of Health and Human Services (HHS) Out-of-Pocket Expenses

Ballard Spahr LLP

Prescription for Chaos: Copay Accumulator Programs Called Into Question

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Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more

Goodwin

Federal Court Strikes Down Copay Accumulator Programs

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On September 29, 2023, the U.S. District Court for the District of Columbia vacated a Trump-era rule from 2021 that allowed insurers to exclude drug manufacturer co-pay support coupons and assistance from a patient’s annual...more

Akerman LLP - Health Law Rx

THE NO SURPRISES ACT: Hoping for an End to the Surprises

By looking at the events that have transpired since the Consolidated Appropriations Act, 2021, which includes the No Surprises Act (the Act), was signed into law, it is clear that the Departments of Health and Human Services,...more

Epstein Becker & Green

Texas Federal Court Issues Fourth Ruling Invalidating Parts of the Administration’s No Surprises Act Regulations

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On August 24, 2023, the U.S. District Court for the Eastern District of Texas issued an opinion and order in Texas Medical Association, et al. v. United States Department of Health and Human Services(“HHS”)(“TMA III”). TMA...more

King & Spalding

First Annual Report on the No Surprises Act’s Impact on the Health Care Market is Released

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On July 6, 2023, the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) released the first of five required annual reports on the impact of the No Surprises Act (NSA) on health care markets (the Report)....more

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

No Surprises Act Guidance on Out-of-Pocket Maximums and Facility Fees

Employers have some new clarity on the No Surprises Act rules on out-of-network providers and charges under new guidance from the U.S. Department of Labor, U.S. Department of the Treasury, and the U.S. Department of Health...more

Akerman LLP - Health Law Rx

Stop – Go – Stop Again – Now GO… Surprised by the No Surprises Act?

We are not surprised by the continued stop-and-go regarding guidance surrounding the No Surprises Act. Most recently, a Texas court vacated portions of the No Surprises Act’s updated final rule (the final rules were discussed...more

Epstein Becker & Green

No Surprises Act: HHS Extends Enforcement Moratorium on Co-Provider & Co-Facility Good Faith Estimates

Epstein Becker & Green on

To the relief of many providers and facilities and with just three weeks to go until the implementation date, the U.S. Department of Health & Humans Services (HHS) announced that it is extending its policy of not enforcing...more

Akerman LLP - Health Law Rx

Finally, More Certainty and Fewer Surprises – Final Rules Issued Under the No Surprises Act

The Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued final rules related to the No Surprises Act on August 26, 2022, to be effective October 25, 2022 (Final Rules).  These Final Rules...more

Dentons

No Surprises Act Frequently Asked Questions: Volume 9

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In 2020, Congress passed the No Surprises Act (NSA) in an attempt to protect uninsured patients from surprise billing. Some sections of the NSA became effective on January 1, 2022, while other sections are on hold until...more

Robinson+Cole Health Law Diagnosis

New Final Rule Under the No Surprises Act Released

On August 19, 2022, the Department of Health and Human Services (HHS), Department of Labor (DOL), and Department of the Treasury (DOT), released “Requirements Related to Surprise Billing: Final Rules” (the Rules). The Rules...more

Manatt, Phelps & Phillips, LLP

Update: No Surprises Act Implementation & CMS Guidance on Vaccination Mandate for Health Care Staff

Editor’s Note: In this article, Manatt Health provides an update on the latest policy developments around the No Surprises Act (NSA) and the vaccination mandate for health care workers....more

King & Spalding

HHS Launches New Reimbursement Program for COVID-19 Vaccine Administration Fees Not Covered by Insurance

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On May 3, 2021, HHS announced a new program to cover the costs of COVID-19 vaccination for patients enrolled in health plans that either do not cover vaccinations generally, or cover them but with patient cost-sharing...more

Sheppard Mullin Richter & Hampton LLP

Trump Administration Finalizes The Transparency in Coverage Rule

On October 29, 2020, the Department of Health and Human Services (“HHS”), the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) released the Transparency in Coverage Final Rules (the...more

Foley & Lardner LLP

Is an Employer’s Health Plan Required to Count the Value of Drug Manufacturer Coupons Towards an Employee’s Out-of-Pocket Maximum?

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Background. These days, almost all employer-sponsored group health plans require an employee (and any dependents) covered under the plan (each are referred to as a “member”) to pay “out-of-pocket” for covered expenses in the...more

Burr & Forman

IRS Expands Preventive Care Benefits Under High Deductible Health Plans

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On July 17, 2019, the Internal Revenue Service (the “IRS”) released Notice 2019-45 which expands the list of permissible preventive care benefits for high deductible health plan (“HDHP”) purposes. Among other requirements, an...more

Sheppard Mullin Richter & Hampton LLP

HHS Proposes Rule to Eliminate Safe Harbor for PBM Drug Rebates

On February 6, 2019, the Office of the Inspector General of the U.S. Department of Health and Human Services (the “OIG”) published in the Federal Register a proposed rule (the “Proposed Rule”) that, if made final in its...more

K&L Gates LLP

K&L Gates Triage: Pharmacy Gag Clauses & Clawbacks

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Pharmacy Benefit Managers (PBMs) are increasingly utilizing gag clauses in pharmacy contracts as a means of prohibiting pharmacies from telling customers that paying for drugs out of pocket would cost them less than if they...more

Holland & Knight LLP

Trump Administration Fiscal Year (FY) 2019 Budget and Healthcare Programs

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The Trump Administration on Feb. 12 released its Fiscal Year (FY) 2019 budget request, titled "An American Budget." Unlike last year's budget, which was released in late May, the release of this budget conforms to the typical...more

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights - July 2016 #4

CMS’ increase of the “income verification threshold” makes eligibility determinations easier for consumers; Oregon CO-OP policyholders can credit out-of-pocket spending towards new plans; and report finds that 13 million...more

McGuireWoods LLP

The Scoop on MOOP: McGuireWoods Healthcare Reform Guide: Installment No. 53

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This is the 53rd in a series of WorkCite articles concerning the Patient Protection and Affordable Care Act and its companion statute, the Health Care and Education Reconciliation Act of 2010 (referred to collectively as the...more

McGuireWoods LLP

Washington Healthcare Update

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This Week: 21st Century Cures Legislation Passes House in Bipartisan Vote... CMS Releases Proposed CY 2016 Home Health Prospective Pay Rule... CMS Releases Final CY 2016 Hospital Outpatient Prospective Payment System (OPPS)...more

Pullman & Comley, LLC

Alert: Health Plan Update on Out-of-Pocket Limitations

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The Affordable Care Act (the “ACA”) established limitations on the annual out-of-pocket costs that a health plan may impose on a participant. The U.S. Department of Health and Human Services, Department of Labor and the...more

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