In August 2023, we published a blog post about the California Office of Health Care Access and Information’s (“OHCA”) proposed cost and market impact review (“CMIR”) regulations under the California Health Care Quality and...more
Welcome to the Payor/Provider Convergence Series of the Health Care Law Today blog. This series is dedicated to exploring the intersection between payors and providers in the health care space; in particular, the evolving...more
Last week, the California Department of Managed Health Care (DMHC) issued an All-Plan Letter (APL) stating that California case law and the Knox-Keene Health Care Service Plan Act of 1975 (the Knox-Keene Act) constitute...more
The DMHC issued its final guidance on the No Surprises Act, confirming that the Knox-Keene Act constitutes a “specified state law” under the Act. The out-of-network reimbursement requirements for emergency services and the...more
On November 4, 2021, the Second District Court of Appeal, Division 2, ruled against establishing tort liability for insurers who paid less than what the hospital believed to be the “reasonable and customary value.” This...more
On December 16, 2020, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR), announced that the Centers for Medicare & Medicaid (CMS) will disallow $200 million in federal Medi-Cal funding next...more
On Friday afternoon, January 24, 2020, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) issued a Notice of Violation to the state of California demanding that the state stop imposing...more
Hospitals that attempt to discharge a patient to a post-acute level of care but are not able to because they cannot find an appropriate accepting facility must continue providing care if the patient cannot be safely...more
On Monday, August 8th, the Deputy Director of Legislative Affairs of the Department of Managed Health Care (the “Department”) released a letter of opposition (the “Letter”) to Assembly Bill 1249 (“AB 1249”). The Letter was...more
The California Department of Managed Health Care (the "DMHC"), which regulates Health Care Service Plans, recently adopted a regulation regarding general licensure requirements for health care providers ("Entities") that...more
On July 1, a new regulation from California’s Department of Managed Health Care (DMHC) will go into effect, and will require health care providers that engage in global risk arrangements to apply for a license or exemption...more
On Friday, June 14, 2019 the Department of Managed Health Care (the “Department”) issued All Plan Letter 19-014 (OLS) (“APL”) containing its formal guidance regarding implementation of the General Licensure Requirements (for...more
After a protracted comment period, the California Department of Managed Health Care (the “Department”) formally adopted its much anticipated “global risk” regulation (the “Regulation”), which will go into effect on July 1,...more
California's Department of Managed Health Care ("DMHC") has proposed regulations that could require accountable care organizations ("ACOs") and other entities that assume "global risk" to obtain licensure as a health care...more
Employee Assistance Programs (or EAPs) have served employers and their employees for decades, providing a variety of benefits to address issues that might otherwise adversely affect the overall health and work of employees. A...more
On June 30, 2014, the Supreme Court of the United States handed down its decision in the Burwell v. Hobby Lobby case, holding that closely-held corporations could refuse to provide contraceptive coverage mandated by U.S....more
Reimbursement for health care services in California continues its shift toward capitation, resulting in health care providers increasingly forming their own health plans under the Knox Keene Health Care Service Plan Act (the...more