News & Analysis as of

Overpayment New Guidance

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

Bricker Graydon LLP on

Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

ArentFox Schiff

Money (That’s What I Want): IRA’s Direct Pay Mechanism Benefits Tax-Exempt Entities

ArentFox Schiff on

The Inflation Reduction Act (IRA), which recently celebrated its one-year anniversary, presents new opportunities for tax-exempt and other organizations to directly benefit from renewable energy tax credits, including...more

Foley & Lardner LLP

Medicaid: New Guidance from CMS Finds there are Significant Misunderstandings on Ground Emergency Medical Transportation...

Foley & Lardner LLP on

On August 17, 2022, the Centers for Medicare and Medicaid Services (CMS) issued a bulletin (Bulletin) to states addressing potentially inappropriate cost-based proposals and practices related to governmental ambulance...more

Holland & Hart - The Benefits Dial

E-P-C-R-S, find out what it means to me … new IRS Correction Guidance

On July 16, 2021, the IRS released updated Employee Plans Compliance Resolution System (EPCRS) guidance for Plan corrections in the form of Rev. Proc. 2021-30. The changes affect the three programs offered by the IRS for...more

Buchalter

IRS Expands Self-Correction under EPCRS and Adds New Overpayment Correction Methods

Buchalter on

On Friday, the IRS issued Revenue Procedure 2021-30 expanding the Employee Plans Compliance Resolution System (“EPCRS”)—a voluntary program for correcting errors in tax-qualified and section 403(b) plans—by adding two new...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 29, Number 43. News Briefs: December 2020

Report on Medicare Compliance 29, no. 43 (December 7, 2020) - In a new provider compliance audit, the HHS Office of Inspector General (OIG) said The Palace at Home, a for-profit home health care agency (HHA) in Miami,...more

McDermott Will & Emery

New Guidance on Medicare Payment Rule Enforcement

McDermott Will & Emery on

A few days before Thanksgiving, the news media published an internal memo by the Office of General Counsel (OGC) at the US Department of Health and Human Services (Department) to officials at the Centers for Medicare and...more

Baker Donelson

New Medicaid DSH Audit Guidance: Its Impact on Pending and Recent State DSH Audits

Baker Donelson on

On December 31, 2018, the Center for Medicaid and CHIP Services issued a notice indicating that CMS was altering its prior audit guidance for Medicaid Disproportionate Share Hospital (DSH) audits that had previously been...more

Holland & Knight LLP

Further ESOP Transaction Guidance Set Forth in Latest DOL Settlement Agreement

Holland & Knight LLP on

On the heels of a recent settlement agreement with an institutional employee stock ownership plan (ESOP) trustee, the U.S. Department of Labor (DOL) and individual trustee James F. Joyner III (Joyner) entered into a...more

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