The Department of Health and Human Services (“HHS”) Centers for Medicare & Medicaid Services (“CMS”) recently issued the final “HHS Notice of Benefit and Payment Parameters for 2026” (hereinafter referred to as the “Rule”)...more
In May, we discussed the final rule on Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs (the “Final Rule”) issued by the Centers for Medicare and...more
On March 4th, the U.S. District Court for the District of Maryland struck down four provisions of the Trump Administration’s Notice of Benefit and Payment Parameters for 2019, 83 Fed. Reg. 16930 (April 17, 2018) (the “Rule”),...more
On February 26, 2021, the Departments of Labor, Health and Human Services (HHS), and the Treasury issued Frequently Asked Questions (FAQs) on the implementation of the Families First Coronavirus Response Act (“FFCRA”), the...more
3/3/2021
/ CARES Act ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Families First Coronavirus Response Act (FFCRA) ,
Health Insurance ,
Insurance Industry ,
Non-Grandfathered Health Plans ,
U.S. Treasury ,
Vaccinations ,
Virus Testing
On October 29, 2020, the Department of Health and Human Services (“HHS”), the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) released the Transparency in Coverage Final Rules (the...more
11/14/2020
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Final Rules ,
Health Insurance ,
Negotiated Rate Agreements ,
Non-Grandfathered Health Plans ,
Out-of-Pocket Expenses ,
Prescription Drug Coverage ,
Pricing Requirements ,
Transparency ,
Trump Administration ,
U.S. Treasury
The Supreme Court issued a long-awaited ruling on April 27, 2020, directed at a more than $12 billion challenge related to the temporary risk corridors program established by the Affordable Care Act (the “ACA”). Challenges...more
4/29/2020
/ Affordable Care Act ,
Appropriations Bill ,
Corporate Counsel ,
Court of Federal Claims ,
Damages ,
Government Payments ,
Health Insurance ,
Insurance Industry ,
Land of Lincoln Mutual Health Insurance Co. v. United States ,
Maine Community Health Options v. United States ,
Moda Health Plan Inc. v. United States ,
Reimbursements ,
Remand ,
Repeal ,
Reversal ,
Risk Corridors Statute ,
SCOTUS ,
Tucker Act
In a much needed sign of bipartisanship, the Senate passed and President Trump signed last night the Families First Coronavirus Response Act. The new law is effective today and requires insurers and group health plans to...more
In a rare act of bipartisanship, Senate Finance Committee Chairman Chuck Grassley, R-Iowa, and Ranking Member Ron Wyden, D-Ore., introduced on July 23rd a chairman’s mark, the Prescription Drug Pricing Reduction Act (PDPRA)...more
7/26/2019
/ Ambulatory Surgery Centers ,
Conflicts of Interest ,
Congressional Budget Office ,
Drug Pricing ,
Health Insurance ,
Hospitals ,
Managed Care Contracts ,
Manufacturers ,
Medicaid ,
Medicare ,
Medicare Part D ,
Outpatient Services ,
Pharmaceutical Industry ,
Pharmacy Benefit Manager (PBM) ,
Physician Fee Schedule ,
Prescription Drug Coverage ,
Prescription Drugs ,
Price Transparency ,
Public Disclosure ,
Rebates ,
Risk-Sharing
On April 10, 2019, the Department of Justice filed notices appealing two District Court rulings that struck down Medicaid work requirements in both Kentucky and Arkansas to the U.S. Court of Appeals for the District of...more
4/26/2019
/ 1115 Waivers ,
Administrative Procedure Act ,
Appeals ,
Arbitrary and Capricious ,
Denial of Insurance Coverage ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Governor Hutchinson ,
Health Insurance ,
Low-Income Issues ,
Medicaid ,
Medicaid Work Requirements ,
Proposed Amendments ,
Remand ,
Secretary of HHS ,
Statutory Authority ,
Take Care Clause ,
Vacated
The Centers for Medicare and Medicaid Services (“CMS”) released the much-anticipated proposed rule to lower Part D and Medicare Advantage (“MA”) drug prices and beneficiary out-of-pocket expenses on November 26, 2018 (the...more
11/29/2018
/ Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Drug Pricing ,
Electronic Prescribing ,
Gag Clauses ,
Health Insurance ,
Health Plan Sponsors ,
Medicare ,
Medicare Advantage ,
Medicare Part D ,
Out-of-Pocket Expenses ,
Pharmaceutical Industry ,
Prescription Drugs ,
Proposed Rules ,
Public Comment