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The Proposed Expansion of Health Reimbursement Arrangements: Is This a Game Changer for Employers?

On October 22, 2018, in perhaps the most significant guidance resulting from President Trump’s 2017 Executive Order 13813, “Promoting Healthcare Choice and Competition Across the United States” (“2017 Executive Order”), the...more

CMS Releases Proposed Rule for ACA Market Stabilization

On February 15, 2017, the Centers for Medicare & Medicaid Services (“CMS”), at the direction of the Trump administration, released a long-expected proposed rule (“Market Stabilization Proposed Rule”)designed to help stabilize...more

CMS Continues to Strengthen Federal-Level Requirements for Qualified Health Plans

On December 2, 2015, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule titled “Patient Protection and Affordable Care Act; CMS Notice of Benefit and Payment Parameters for 2017” (“Proposed...more

HHS Releases Far-Reaching Proposed Rule to Prohibit Discrimination by “Covered Entities” Pursuant to Section 1557 of the...

On September 8, 2015, the U.S. Department of Health and Human Services (“HHS”) published a proposed rule titled “Nondiscrimination in Health Programs and Activities” (“Proposed Rule”)[1] to implement the nondiscrimination...more

Mental Health Parity Requirements and Medicaid Plans: CMS Seeks Comment on Proposed Rule

On April 10, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published in the Federal Register a proposed rule (“Proposed Rule”) implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction...more

Obama Administration Seeks Comments on Proposed Changes to Summary of Benefits and Coverage Document and Requirements

On December 30, 2014, the Departments of Health and Human Services, Labor, and the Treasury (collectively, “Departments”) issued a proposed rule (“Proposed Rule”) regarding the summary of benefits and coverage (“SBC”) for use...more

Proposed Exemption of Limited Wraparound Coverage from Health Insurance Market Standards

On December 19, 2014, various federal agencies issued proposed regulations (“Proposed Regulations”) to amend the definition of “excepted benefits” to include certain limited wraparound health insurance coverage. “Excepted...more

HHS Broadens Federal Controls Over Private Health Insurance Benefits and Operations

On November 21, 2014, the Obama administration released two proposed rules affecting health insurance issuers’ offering of private health insurance products both inside and outside of the public insurance exchanges...more

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