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Department of Health and Human Services (HHS) Safe Harbors Penalties

Venable LLP

OIG Reminds Us that Flat Fee Business Arrangements Aren’t Immune from AKS Scrutiny

Venable LLP on

On July 1, 2025, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 25-08, concluding that a medical device manufacturer’s proposed payment to access a...more

Perkins Coie

The Affordable Care Act’s “Play Or Pay” Mandate: How It Works

Perkins Coie on

The Affordable Care Act added the so-called “Play or Pay” mandate or “Employer Shared Responsibility” provisions to the Internal Revenue Code (the Code). Starting in 2014, certain employers may be subject to a penalty tax,...more

Proskauer Rose LLP

IRS Releases Proposed Regulations on the Affordable Care Act's Play or Pay Mandate

Proskauer Rose LLP on

On January 2, 2013, the Department of Treasury and Internal Revenue Service (collectively “IRS") published proposed regulations ("Proposed Regulations") on the Affordable Care Act's employer shared responsibility provisions,...more

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