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IRS, Treasury Department Issue Proposed Rules Governing Minimum Value, Affordability, and Wellness Programs

A key policy goal of the Patient Protection and Affordable Care Act (the “Act”) is the expansion of health insurance coverage to all Americans. The concepts of “minimum value” and its correlate “actuarial value” speak to the...more

Staffing Industry Compliance with the Employer Shared Responsibility (aka “Pay-or-Play”) Provisions of the Affordable Care Act:...

Under the Patient Protection and Affordable Care Act (the “Act”), the federal government, state governments, insurers, employers, and individuals all share responsibility to make affordable health insurance coverage widely...more

On the Manifold Meanings of "Affordability" According to the Patient Protection and Affordable Care Act

The core policy goals of the Patient Protection and Affordable Care Act (the “Act”)—on which there is near universal consensus—are threefold: expand health care coverage; increase the quality of medical outcomes, and reduce...more

Agencies Issue Proposed Regulations Implementing the 90-Day Waiting Period Limitation Under the Affordable Care Act

On March 21, 2013, the Departments of the Treasury/IRS, Labor, and Health and Human Services (the “Departments”) issued a proposed regulation implementing the 90-day waiting period limitation under Section 2708 of the Public...more

The New HIPAA Omnibus Rule & Your Liability — A Detailed Review

As we have reported in this blog, the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently released final regulations containing modifications to the HIPAA Privacy, Security, Enforcement, and...more

DOL, IRS, and HHS Put the Brakes on Stand-Alone HRAs Used to Access Health Insurance Coverage in the Individual Market

In a set of Frequently Asked Questions (FAQs) posted to the Department of Labor’s website on January 24, the Departments of Health and Human Services, Labor, and Treasury (the “Departments”) put a stop to an approach to...more

IRS/Treasury Issue Employer Shared Responsibly Proposed Regulations

Beginning in 2014, the Patient Protection and Affordable Care Act (Act) requires “applicable large employers” (i.e., employers with 50 or more full-time equivalent employees) to either offer group health insurance coverage to...more

HHS Issues Proposed Regulations Implementing Reinsurance Fees Paid by Carriers and Group Health Plans Under the Affordable Care...

The Patient Protection and Affordable Care Act (Act) fundamentally changes the way that health insurance is regulated in the United States. These changes are part of an ambitious statutory scheme that comprehensively reforms...more

HHS Issues Comprehensive “Essential Health Benefits” Proposed Regulations

Commencing in 2014, the Patient Protection and Affordable Care Act (Act) requires that health insurance coverage provided in the individual and small group markets, including coverage offered through American Health Benefit...more

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