News & Analysis as of

Department of Health and Human Services (HHS) Subsidies

Morgan Lewis - Health Law Scan

Manufacturers Should Carefully Evaluate OIG’s Approval of Medicare Cost Sharing Subsidies in Clinical Trials

At the end of last year, the US Department of Health and Human Services Office of Inspector General (OIG) issued an Advisory Opinion (AO 23-11, the Opinion) in which OIG approved an arrangement where a medical device...more

Ballard Spahr LLP

Prescription for Chaos: Copay Accumulator Programs Called Into Question

Ballard Spahr LLP on

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

Dentons

COBRA Premium Subsidies Under the American Rescue Plan Act

Dentons on

The American Rescue Plan Act requires employers to subsidize 100% of the cost of COBRA and comparable state continuation coverage for “assistance eligible individuals” from April 1, 2021, through September 30, 2021. The...more

Hogan Lovells

OIG denies proposed manufacturer-sponsored copay support program for Medicare beneficiaries

Hogan Lovells on

On September 23, the HHS OIG published Advisory Opinion No. 20-05, advising that OIG found “highly suspect” a manufacturer’s proposal to create a copay subsidy program to help certain financially eligible Medicare...more

Holland & Knight LLP

OIG Rescinds Advisory Opinion

Holland & Knight LLP on

The Department of Health and Human Services Office of Inspector General (the OIG), on November 28, 2017, issued a Rescission Letter terminating Advisory Opinion Number 06-04 (Advisory Opinion 06-04). In Advisory Opinion...more

Fisher Phillips

President Trump Once Again Attempts To Dismantle The Affordable Care Act

Fisher Phillips on

After multiple failed attempts by Congress to reform the Affordable Care Act (ACA), President Trump announced several weeks ago that the federal government would stop making subsidy payments to insurers who sell coverage...more

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights - April 2017 #2

HHS's position on cost-sharing reduction payments remains unclear as insurers seek certainty before Marketplace rate filing deadlines; states continue to finalize Medicaid budgets and seek waiver flexibility; and North...more

King & Spalding

Also In The News - Health Headlines - December 2016

King & Spalding on

CMS Releases the Finalized Medicare Outpatient Observation Notice Form – On December 9, 2016, CMS released the final Medicare Outpatient Observation Notice (MOON) form. The MOON form is a standardized form developed by CMS...more

Cadwalader, Wickersham & Taft LLP

The Trump Administration: The Future of Health Care

The election of Donald J. Trump as the 45th President of the United States, along with the Republican control of the majority of both the House of Representatives and the Senate, will likely set in motion a major overhaul of...more

Proskauer Rose LLP

Repealing and Replacing the ACA: Five Developments Likely to Occur in the Years Ahead

Proskauer Rose LLP on

On the back of the 2016 United States presidential election results, the health care industry ponders how a Republican president and Congress will transform the business environment. The health care industry has a number of...more

Mintz - Employment Viewpoints

Student Health Insurance Subsidies Catch Another Break

On October 21, 2016, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively, the Departments) issued a FAQ providing indefinite relief for employers who subsidize student health...more

Baker Donelson

OIG Approves Transportation Assistance Program

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On October 3, 2016, the U.S. Department of Health & Human Services, Office of the Inspector General (OIG), issued an advisory opinion approving a local health care district’s proposal to cooperate with another district to...more

BCLP

We Received an Exchange Subsidy Notice…Now What?

BCLP on

The Affordable Care Act exchanges/marketplaces are required to notify employers of any employees who have been determined eligible for advance payments of the premium tax credit or cost-sharing reductions (i.e., subsidy) and...more

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights - July 2016 #2

The President voices support for a public option; Vermont selects a Medicaid ACO; and Alabama ends enhanced primary care reimbursements....more

Balch & Bingham LLP

Healthcare.gov: No 2015 Employer Subsidy Notices

Balch & Bingham LLP on

On September 18, 2015, the Centers for Medicare and Medicaid Services (CMS) published a set of “Frequently Asked Questions Regarding the Federally-Facilitated Marketplace’s (FFM) 2016 Employer Notice Program.”...more

Balch & Bingham LLP

Outside Counsel Should Handle Healthcare.gov Subsidy Appeals

Balch & Bingham LLP on

Here’s the coming dilemma: let IRS assess employer mandate taxes based on errant Healthcare.gov subsidy certifications or appeal those errors to prevent those assessments.  “Where’s the dilemma?” you say.  Here:  once you...more

Baker Donelson

OIG Approves Subsidies to Medicare Beneficiaries Provided by a Clinical Research Study

Baker Donelson on

On May 28, 2015, the U.S. Department of Health & Human Services, Office of Inspector General (OIG) issued an advisory opinion approving a medical device manufacturer’s proposed arrangement to provide subsidies to certain...more

Mintz - ML Strategies

Health Care Update - March 2015

Mintz - ML Strategies on

In This Issue: - King v. Burwell before the Supreme Court and the Potential Congressional Response - Implementation of the Affordable Care Act - Other Federal Regulatory Initiatives - Congressional...more

McGuireWoods LLP

Washington Healthcare Update

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This Week: President’s FY2016 Budget Request... FDA Commissioner Hamburg to step down... Tennessee Medicaid expansion plan rejected by legislature. 1. Congress House House Ways and Means Committee Hosts Hearing...more

Franczek P.C.

Monthly Benefits Update - November 2014

Franczek P.C. on

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

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights: December 2014

This week, a federal Issuer Bulletin describes how issuers in the Federally Facilitated Marketplace will identify their existing enrollees who are switching plans for 2015 coverage. The Exchange Board in New Mexico proposes a...more

Cozen O'Connor

Health Care Reform Implementation Update

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Congress is in recess and therefore much of the action surrounding the Affordable Care Act (ACA) is at the agency level. However, Congressman Darrel Issa (R-CA) did subpoena the U.S. Department of Treasury for their records...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

Carlton Fields

The Affordable Care Act Comes Of Age

Carlton Fields on

Since President Obama signed the Patient Protection and Affordable Care Act (ACA) in March 2010, various provisions of the law have taken effect. However, its core pieces become effective this year....more

Ballard Spahr LLP

HHS Says Qualified Health Plans Are Not ‘Federal Health Care Programs’

Ballard Spahr LLP on

The Department of Health and Human Services (HHS) recently announced that qualified health plans (QHPs) established by the Affordable Care Act (ACA)—which include federally-facilitated insurance exchanges and federal...more

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