When you have a fully insured health plan, you might think you don’t have a viable way to reduce benefits costs. After all, you can’t access the data analytic insights you would see if you were self-funded. But switching to...more
Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2023 deadline for paying fees that fund the Patient-Centered Outcomes...more
The Centers for Medicare & Medicaid Services (CMS) Innovation Center continues to move forward with its “strategic refresh” initiative. CMS’s strategic refresh initiative aims to meet five objectives: drive accountable care,...more
We follow up on our previous blog post concerning the U.S. Supreme Court’s unanimous ruling in favor of 340B hospitals. The Supreme Court previously held that “absent a survey of hospitals’ acquisition costs, HHS may not vary...more
On May 21, 2021, SavaSeniorCare LLC and several of its affiliates, which own and operate skilled nursing facilities across the country, agreed to pay $11.2 million to resolve claims that the companies billed Medicare for...more
On March 27, 2020, the Texas Supreme Court, in Farmers Texas County Mutual Insurance Company v. Beasley, No. 18-0469, decided whether “an injured plaintiff had standing to bring suit against his personal injury protection...more
The State of Maryland is unique in its historical experimentation with rate setting and global budgets for hospitals, and that experimentation continues with the Maryland Total Cost of Care Model (TCOC). Beginning January...more
The Trump administration and Republican-led Congress spent substantial time and political capital in 2017 on efforts to repeal and replace the Affordable Care Act (ACA) and enact sweeping Medicaid reform. By the end of the...more
Until very recently, employers were at risk of receiving steep fines if they reimbursed employees for non-employer sponsored medical care – the Affordable Care Act (ACA) included fines of up to $36,500 a year per employee for...more
The promise of health care reform by the incoming administration will result in significant changes; but understanding how those changes may flow through to digital health industry requires an analytic framework that...more
Employers have plenty on their plates to think about on the subject of wellness plans these days. New EEOC regulations and new court decisions will keep employers on their toes in evaluating their current wellness plan...more
On December 16, 2015, the Internal Revenue Service issued Notice 2015-87 containing guidance on a wide-range of topics under the Affordable Care Act (ACA). In addition to providing guidance on affordability and COBRA matters...more
Under so-called “employer payment plans” (“EPPs”), an employer pays or reimburses an employee for substantiated premium costs under individual health plan insurance coverage (i.e., nonemployer individual health plan...more
Any employer who offers an arrangement that reimburses employees (or pays directly) for premiums or other medical costs of individual health insurance coverage, including a health reimbursement account ("HRA") provided in...more
Beginning in 2014, a violation of certain healthcare reform rules, such as offering a health plan with annual dollar limits or not providing full preventive care with no employee cost, requires employers to pay an excise tax...more
Prior to the passage of the Affordable Care Act ("ACA") in 2010, employers were able to reimburse their employees for the premiums those employees paid for individual health insurance. This long-standing practice was changed...more
The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more
The Internal Revenue Service (IRS) recently issued additional guidance (Notice 2015-17) addressing the treatment of arrangements whereby an employer reimburses an employee for some or all of the premium expenses incurred for...more
In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more
Last week, the IRS announced the waiver (for 2014 and the first half of 2015) of the penalty for “small” employers that reimburse employees for individual health insurance premiums. To the IRS, “small employer” means an...more
Last month, CMS updated its FAQs related to the two midnight rule. In additional, CMS conducted two recent Open Door Forum Calls related to the new rule. Some of the highlights from the updated FAQs and calls are discussed...more
After receiving many comments on its Draft Call Letter, CMS published its Contract Year 2014 Final Call Letter on April 1, 2013. The Final Call Letter addresses a wide variety of issues that will affect all parties involved...more
Overview - In Part I of this series, I discussed the benefits of collective bargaining agreements for small business owners and professional corporations for qualified retirement planning. The ability to unionize...more
Last year's Health Reform Act prohibited tax-free reimbursement of over-the-counter medicines obtained without a prescription (other than insulin) by health care flexible spending accounts (FSA) and health care reimbursement...more