News & Analysis as of

Safe Harbors Department of Health and Human Services (HHS) Patient Protection and Affordable Care Act (PPACA)

Jackson Lewis P.C.

Transparency in Coverage Enforcement

Jackson Lewis P.C. on

On April 19, 2022, the Departments of Labor, Health and Human Services, and the Treasury issued additional guidance under the Transparency in Coverage Final Rules issued in 2020. The guidance, FAQs About Affordable Care Act...more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Mintz - Employment Viewpoints

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more

Burr & Forman

IRS Expands Preventive Care Benefits Under High Deductible Health Plans

Burr & Forman on

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

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

McDermott Will & Emery

New OIG Rules Change Patient Incentive Program Landscape: Where Are the Limits Now?

McDermott Will & Emery on

With health care becoming more consumer-driven, health care providers and health plans are wrestling with how to incentivize patients to participate in health promotion programs and treatment plans. As payments are...more

McDermott Will & Emery

New OIG Exclusion Regulations About to Go into Effect

The Office of Inspector General (OIG) recently published a final rule regarding its exclusion authorities. The final rule goes into effect March 21, 2017, and expands OIG’s authority to exclude certain individuals and...more

Roetzel & Andress

Health Law Insights: January Newsletter

Roetzel & Andress on

ALERT: Health Reform Outlook for 2017: A Year of Major Uncertainty - Fulfilling their promises, Congressional Republicans moved to repeal the Affordable Care Act (ACA) on the first day of the new Congress when Senate...more

Akerman LLP

New Year, New Resolutions, New Safe Harbors

Akerman LLP on

As we welcome the new year and its endless possibilities, we also welcome some new Anti-Kickback Statute safe harbors and concomitant business possibilities. In December, the U.S. Department of Health and Human Services...more

Hogan Lovells

HHS OIG Finalizes New Exclusion Rules as Administration Exits

Hogan Lovells on

With just a week left before a new administration takes office, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) finalized changes to the regulations authorizing OIG to exclude...more

McDermott Will & Emery

Money Talks: Important Takeaways from the OIG’s Civil Monetary Penalties Final Rule

McDermott Will & Emery on

In a burst of rulemaking in December 2016, the US Department of Health and Human Services, Office of Inspector General, issued two new final rules containing significant changes to OIG’s Civil Monetary Penalty authorities....more

BakerHostetler

Providers Breathe Sigh of Relief with New Anti-Kickback Safe Harbors and CMP Exceptions

BakerHostetler on

On December 7, 2016, the HHS Office of Inspector General (OIG) finalized a set of rules first proposed in 2014 adding new anti-kickback law safe harbors and protecting additional conduct from enforcement under the civil...more

Saul Ewing LLP

OIG Revises and Adds Anti-Kickback Statute Safe Harbors and Civil Monetary Penalty Rules

Saul Ewing LLP on

In what may be one of the final federal health care revisions implemented during the Obama Administration, on December 7, 2016 the U.S. Department of Health and Human Services (“HHS”), Office of Inspector General (“OIG”),...more

Seyfarth Shaw LLP

Issue 104: Departments Issue FAQs on the Mental Health Parity and Addiction Equity Act and Request Comments on Tobacco Cessation...

Seyfarth Shaw LLP on

On October 26, 2016, the Departments of Health and Human Services, Labor and Treasury (the Departments) published issue 34 of their series of FAQs on the Affordable Care Act, found here. The FAQs discuss the Mental Health...more

McDermott Will & Emery

OIG Revises Safe Harbors under the Anti-Kickback Statute and Civil Monetary Penalty Rules Regarding Beneficiary Inducements

McDermott Will & Emery on

On December 7, 2016, the Office of Inspector General of the US Department of Health and Human Services published a final rule containing revisions to both the federal Anti-Kickback Statute safe harbors and the beneficiary...more

Mintz - Health Care Viewpoints

At Long Last, OIG Issues Final Rule for Beneficiary Inducement Safe Harbors

More than two years since issuing the proposed rule, the HHS Office of the Inspector General (OIG) issued the long-awaited and highly anticipated final rule (the Final Rule) that provides amendments to the Anti-Kickback...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - September 2015

Proskauer Rose LLP on

Editor's Overview - It has been a little more than one year since the U.S. Supreme Court altered the legal landscape for litigating ERISA breach of fiduciary duty claims relating to the investment in employer stock...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

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

Cozen O'Connor

Health Care Reform Implementation Update - April 26, 2013

Cozen O'Connor on

Marilyn Tavenner received bipartisan support from members of the Senate Committee on Finance in her confirmation hearing to lead the Centers for Medicare and Medicaid Services (CMS) though a full Senate vote is being held up,...more

Baker Donelson

IRS Issues Proposed Regulations for Employer-Shared Responsibility under ACA

Baker Donelson on

On December 28, 2012, the IRS issued proposed regulations with respect to employer-shared responsibility regarding health coverage under the Affordable Care Act of 2010 (ACA). Employers are permitted to rely on these proposed...more

Perkins Coie

The Affordable Care Act’s “Play Or Pay” Mandate: How It Works

Perkins Coie on

The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...more

Proskauer Rose LLP

IRS Releases Proposed Regulations on the Affordable Care Act's Play or Pay Mandate

Proskauer Rose LLP on

On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more

Pillsbury Winthrop Shaw Pittman LLP

Wellness Programs: Keeping Up With the Times

On November 20, 2012, the IRS, DOL and HHS jointly issued proposed regulations under the Affordable Care Act building on existing HIPAA regulations of wellness programs. The new proposed regulations provide clearer guidance...more

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