News & Analysis as of

Consolidated Appropriations Act (CAA) Healthcare

Ballard Spahr LLP

Courts Split on Enforcement of No Surprises Rules

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The Fifth Circuit and the Federal District Court of Connecticut have issued conflicting decisions on whether service providers may sue to enforce arbitration awards under the No Surprises Rules in the Consolidated...more

King & Spalding

Congress Considering Bipartisan Legislation to Expand Medicare GME Programs

King & Spalding on

On December 18, 2024, a bipartisan group of four Senators on the Senate Finance Committee released draft legislation that would expand the total number of Medicare Graduate Medical Education (GME) full-time equivalent (FTE)...more

Davis Wright Tremaine LLP

COVID-19 Telehealth Flexibilities Extending and Enduring

In the wake of an end of year filled with intense negotiations and political wrangling, Congress has successfully enacted the American Relief Act, 2025 ("the Budget Bill" or "legislation"), narrowly averting a government...more

Akin Gump Strauss Hauer & Feld LLP

A New Year, Congress and Trump Administration: 10 Health Issues to Watch in 2025

As the new year begins, change is afoot inside the Beltway as the 119th Congress gets underway and Washington prepares for President Trump’s second administration. While change is bringing uncertainty on some fronts, health...more

Sheppard Mullin Richter & Hampton LLP

Congress Extends Telehealth Flexibilities for Two More Years

With only two weeks remaining in the year, Congress is considering a government funding deal (the “Further Continuing Appropriations and Disaster Relief Supplemental Appropriations Act, 2025” or the “Bill”) that includes a...more

Snell & Wilmer

Deadline Approaches for Expiring Medicare Telehealth Waivers: What Providers Should Know

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During the COVID-19 pandemic, both federal and state governments enacted a host of laws and implemented flexibilities to ensure health care providers, hospitals, and health systems could move traditional brick-and-mortar care...more

McDermott+

No Surprises Act Implementation Under the Trump Administration

McDermott+ on

The No Surprises Act, a law that ended the practice of “balance billing” by certain out-of-network providers, was enacted as part of the Consolidated Appropriations Act of 2021 on December 27, 2020. While the law passed...more

McDermott+

Virtual Care Policy Update: What to Expect in Lame Duck

McDermott+ on

Updated November 18, 2024 – The Consolidated Appropriations Act (CAA), 2023 (Public Law 117-328), signed into law on December 29, 2022, extended certain key telehealth flexibilities instituted during the COVID-19 public...more

Alston & Bird

Final Mental Health Parity Rules: A Plan Sponsor’s Implementation Guide

Alston & Bird on

Our Employee Benefits & Executive Compensation Group discusses what health plan sponsors need to know about the final rule on nonquantitative treatment limitations (NQTLs) and NQTL comparative analysis under the Mental Health...more

Ballard Spahr LLP

Surprise, Surprise! No Surprise Billing Regulations Upheld

Ballard Spahr LLP on

The Fifth Circuit Court of Appeals recently upheld regulations defining the qualifying payment amount (QPA). The QPA is a key factor in determining how much individuals and health plans must pay out-of-network providers in...more

McDermott+

Virtual Care Policy Update: What to Expect in Lame Duck

McDermott+ on

The Consolidated Appropriations Act (CAA), 2023 (Public Law 117-328), signed into law on December 29, 2022, extended certain key virtual care flexibilities instituted during the COVID-19 public health emergency (PHE) through...more

McDermott Will & Emery

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

McDermott Will & Emery on

On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more

McDermott+

Telehealth: Regulatory Questions Amid Legislative Uncertainty

McDermott+ on

Where has the time gone? We have hit the one-year mark since the end of the COVID-19 public health emergency (PHE). Yes, you read that correctly. One year! One of the long-term consequences of the PHE was the shift in when...more

Bass, Berry & Sims PLC

Welfare Plan Class Action Litigation Underscores Importance of Minding Your Fiduciary Duties

Bass, Berry & Sims PLC on

As mentioned in our recent blog post, the recently filed class action lawsuit against Johnson & Johnson (Lewandowski v. Johnson & Johnson et. al., D.N.J., No. 1:24-cv-00671 (Feb. 5, 2024)) over alleged excessive prescription...more

Akin Gump Strauss Hauer & Feld LLP

Compacts Renewal Ushers in New Era of Relations Between the U.S. and Freely Associated States

When President Biden signed the Consolidated Appropriations Act into law on March 9, he dramatically altered U.S. relationships with the Republic of the Marshall Islands (RMI), the Republic of Palau, and the Federated States...more

Littler

Sponsoring a Group Health Plan for Employees? What Employers Need to Know About the Consolidated Appropriations Act

Littler on

Many employers offer health insurance as a way to recruit and retain talent. Sponsoring a group health plan, however, can subject the employer plan sponsor to significant legal and regulatory burdens deriving from laws such...more

McDermott+

Regulatory Reflections from the Past Year

McDermott+ on

As 2023 comes to a close, I can’t help but reflect on all the regulations and policies we reviewed this year (and those that we’ll continue to handle next week before the year actually ends). There were some tasty eggs with...more

Nelson Mullins Riley & Scarborough LLP

CMS Issues Interim Rule in Response to State Medicaid Disenrollment Trend

When the COVID-19 Public Health Emergency (PHE) ended in April 2023, the Families First Coronavirus Response Act’s Medicaid continuous enrollment condition also came to an end. The condition had allowed states to claim a...more

Foley Hoag LLP - Medicaid and the Law

CMS Issues Rule Implementing Medicaid Redetermination Policies

We’ve written recently about the process that states are undertaking to begin to wind down the Medicaid enrollment expansion that was necessitated by the enactment of the Families First Coronavirus Response Act in March of...more

Constangy, Brooks, Smith & Prophete, LLP

Update on Cyber Incident Reporting for Critical Infrastructure Act of 2022

As we near the end of another year, it is time to look ahead to developments in the information security and privacy landscape. One area of particular importance is the development of regulations implementing the Cyber...more

Ballard Spahr LLP

No Surprises, But Much Uncertainty: The Status of CAA Billing Rules

Ballard Spahr LLP on

Summary - The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy....more

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Ballard Spahr LLP

Attestation to Consolidated Appropriations Act’s “Anti-Gag Rules” Due by Year’s End

Ballard Spahr LLP on

By December 31, 2023, health plans and insurers must submit an attestation of compliance with the “anti-gag rules” of the Consolidated Appropriations Act of 2021 (CAA). The rules apply to all agreements entered into on or...more

Nelson Mullins Riley & Scarborough LLP

Physician Wellness Program Exception

On Dec. 29, 2022, the Consolidated Appropriations Act (the “CAA”) was signed into law. The CAA provides for a new exception to the Stark Law and Anti-Kickback Statute (the “AKS”). Section 4126 of the CAA introduces a new...more

ArentFox Schiff

Physician Wellness Programs: A New Stark Law Exception and AKS Safe Harbor to Combat Burnout

ArentFox Schiff on

The recently passed Consolidated Appropriations Act (CAA) of 2023 includes a new Stark Law exception and Anti-Kickback Statute (AKS) safe harbor, allowing hospitals and other health care entities to offer their physicians...more

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