On July 25, 2023, HHS, the Department of Labor, and the Department of the Treasury (the Departments) issued proposed rules (Proposed Rules) and other information regarding health plan and issuer compliance with mental health...more
8/7/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Health Insurance ,
Mental Health ,
MHPAEA ,
NQTLs ,
Proposed Rules ,
Substance Abuse ,
U.S. Treasury
On April 5, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule (CMS-4201-F) regarding the Medicare Advantage (MA) and Part D programs. The Final Rule includes changes related to various aspects of...more
4/10/2023
/ Centers for Medicare & Medicaid Services (CMS) ,
Continuity of Care ,
Department of Health and Human Services (HHS) ,
Final Rules ,
Health Care Providers ,
Medical Necessity ,
Medicare Advantage ,
Medicare Part D ,
OIG ,
Regulatory Agenda ,
Regulatory Requirements ,
Two-Midnight Rule
On October 3, 2022, the Attorneys General for California, New York, and Massachusetts, in collaboration with Attorneys General from 18 other states and the District of Columbia (State Attorneys General) submitted a comment...more
10/14/2022
/ Affordable Care Act ,
Algorithms ,
Anti-Discrimination Policies ,
Decision-Making Process ,
Department of Health and Human Services (HHS) ,
Healthcare ,
Medicaid ,
Medicare ,
Proposed Rules ,
Request For Information ,
Risk Mitigation ,
State Attorneys General
OIG periodically makes updates to its Integrity Agreement (IA) and Corporate Integrity Agreement (CIA) model language. It is important for healthcare organizations – even those not subject to a CIA – to monitor changes to...more
Last week, HHS withdrew the SUNSET rule, which, in general, would have caused HHS regulations to expire unless reviewed or assessed every 10 years. As previously reported (see here and here), the Biden administration twice...more
On July 7, 2021, OIG posted Advisory Opinion No. 21-07 relating to a proposed arrangement between a Medigap Plan and a Preferred Hospital Organization (PHO). The proposed arrangement involves (i) a discount on policyholder’s...more
On September 21, 2020, the HHS Office of Civil Rights (OCR) announced a $1.5 million settlement with Athens Orthopedic Clinic, a Georgia orthopedic clinic, to settle potential violations of the Health Insurance Portability...more
In March, OIG released its annual Medicaid Fraud Control Units (MFCUs) report for Fiscal Year (FY) 2018. MFCUs investigate and prosecute Medicaid provider fraud and patient abuse and neglect and are jointly funded by the...more
On July 31, 2017, the United States District Court for the District of Connecticut certified a nationwide class of Medicare beneficiaries in an action against HHS regarding whether patients can appeal their status as an...more
On March 27, 2017, in conjunction with the Health Care Compliance Association (“HCCA”) annual Compliance Institute (“CI”), the Department of Health and Human Services (“HHS”), Office of the Inspector General (“OIG”) released...more
On September 16, 2016, approximately 112 congressional representatives submitted a letter to HHS Secretary Sylvia Matthews Burwell and CMS acting Administrator Andy Slavitt requesting that CMS not implement its proposal...more