News & Analysis as of

Out-of-Pocket Expenses Patient Protection and Affordable Care Act (PPACA)

Woodruff Sawyer

IRS Releases 2026 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits

Woodruff Sawyer on

In Rev. Proc. 2025-19, the IRS released the inflation adjusted amounts for 2026 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs).  In Rev. Proc. 2025-19, the IRS released the inflation...more

Mintz - Health Care Viewpoints

CMS’s ACA Marketplace Integrity and Affordability Proposed Rule – What it may mean for Health Plans

Earlier this month, the Centers for Medicare & Medicaid Services (CMS) released its 2025 Marketplace Integrity and Affordability Proposed Rule (Proposed Rule), proposing a number of enrollment and eligibility policies...more

Bass, Berry & Sims PLC

CMS & HHS Withdraw Appeal to Recent Copay Accumulator Federal District Court Decision: 2020 Accumulator Rule Still in Effect

On January 16, the Centers for Medicare & Medicaid Services (CMS) & the U.S. Department of Health and Human Services (HHS) withdrew an appeal to a recent copay accumulator court decision, HIV and Hepatitis Policy Institute et...more

McDermott+

CMS Issues Two Health Plan Proposed Regs: Different Markets but Similar Policy Goals

McDermott+ on

Before the Thanksgiving holiday, the Centers for Medicare & Medicaid Services (CMS) issued two proposed regs that would make changes to certain health insurance plan policies starting in 2025: one impacting Medicare Advantage...more

Ballard Spahr LLP

Prescription for Chaos: Copay Accumulator Programs Called Into Question

Ballard Spahr LLP on

Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more

Davis Wright Tremaine LLP

New FAQs Address No Surprises Act Impact on ACA Maximum Out-of-Pocket Limits and Facility Fee Transparency

Employers should be aware that the No Surprises Act has an impact on the maximum-out-of-pocket ("MOOP") limit for annual cost-sharing under the Affordable Care Act ("ACA") and facility fee transparency. The new set of...more

McDermott Will & Schulte

Are Out-of-Pocket Costs on Their Way Out? At-Home COVID-19 Testing and Expanded Preventative Healthcare for Women and Children

In response to a directive from the White House, based on provisions of the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief and Economic Security (CARES) Act that eliminated cost sharing for...more

Sheppard Mullin Richter & Hampton LLP

CMS’s Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs

On January 6, 2022, the Centers for Medicare and Medicaid Services (“CMS”) issued the proposed rule on Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs...more

Sheppard Mullin Richter & Hampton LLP

Biden Administration Finalizes Lower Out-of-Pocket Costs for Exchange Plans, Targets Health Equity and Access

The Biden Administration used the annual rulemaking that governs health plans sold on the Affordable Care Act’s exchanges to lower health care costs for consumers and improve access to health care. Part 2 of the Notice of...more

Seyfarth Shaw LLP

Sad Day for Coupon-Clippers

Seyfarth Shaw LLP on

Seyfarth Synopsis: Recently, the Trump Administration issued its proposed Notice of Benefit & Payment Parameter for 2021 regulations....more

King & Spalding

Strategies for Addressing Reference-Based Plans

King & Spalding on

The move by some employer plans to a “reference-based” pricing model has created a need for healthcare providers to develop a strategy to confront payment challenges that these plans create. A prevalent model of...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Employers May Need to Provide Cost Data Under Proposed ACA Rules

Employer-sponsored health plans and health insurers may be required to post online - and to provide participants upon request - a range of pricing and cost-sharing information beginning in 2021. Proposed Affordable Care...more

Snell & Wilmer

Preventive Care Can Now Be Covered for Specified Chronic Conditions Before HDHP Deductible

Snell & Wilmer on

On July 17, 2019 the IRS released Notice 2019-45 resolving a preventive care problem that has been plaguing many high deductible health plans (“HDHPs.”). The Affordable Care Act’s free preventive care mandate appears to be...more

Burr & Forman

IRS Expands Preventive Care Benefits Under High Deductible Health Plans

Burr & Forman on

On July 17, 2019, the Internal Revenue Service (the “IRS”) released Notice 2019-45 which expands the list of permissible preventive care benefits for high deductible health plan (“HDHP”) purposes. Among other requirements, an...more

Proskauer - Employee Benefits & Executive...

IRS Announces HSA and HDHP Limitations for 2020

On May 28, 2019, the IRS released Revenue Procedure 2019-25 setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2020. HSAs are subject to annual aggregate contribution...more

Fisher Phillips

Reference-Based Pricing: Another Self-Insured Option for Employers

Fisher Phillips on

As health care costs increase, employers have been exploring new types of health coverage options, one of which is reference-based pricing (RBP). This method typically does not involve a traditional insurance carrier or...more

Proskauer - Employee Benefits & Executive...

IRS Announces HSA and HDHP Limitations for 2019

On May 10, 2018, the IRS released Revenue Procedure 2018-30 setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2019. HSAs are subject to annual aggregate contribution...more

Mintz - Health Care Viewpoints

Health Care Weekly Preview from ML Strategies – April 2018 #2

The President was slated to speak on drug prices this week in what was a highly anticipated event. Yesterday, word got out that it would be postponed to a date to be determined. The health of the HHS Secretary certainly...more

Ruder Ware

Let’s Start Over – 2018 Health Savings Account Cost of Living Adjustments

Ruder Ware on

It is unusual for the IRS to implement a retroactive change to a previously announced limit (whether it be qualified plan limits or HSA limits). Especially when the change is a reduction in the amount that taxpayers can...more

Holland & Knight LLP

Trump Administration Fiscal Year (FY) 2019 Budget and Healthcare Programs

Holland & Knight LLP on

The Trump Administration on Feb. 12 released its Fiscal Year (FY) 2019 budget request, titled "An American Budget." Unlike last year's budget, which was released in late May, the release of this budget conforms to the typical...more

K&L Gates LLP

K&L Gates Triage: An Insider’s Perspective on the Health Care Debate in Washington, DC

K&L Gates LLP on

In this episode of Triage, Amanda Makki and Corbin Santo of the K&L Gates Public Policy and Law practice group discuss several fundamental issues that are currently at the center of the health care debate in Washington, DC....more

Proskauer - Employee Benefits & Executive...

Updated Health Care Reform Legislation Comparison Chart

The chart below compares key provisions of the Affordable Care Act (ACA), the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BCRA). This chart is current as of July 13, 2017, and as of that date,...more

Epstein Becker & Green

HHS Sets New Requirements to Limit Surprise Medical Bills from Out-of-Network Providers

Epstein Becker & Green on

The U.S. Department of Health and Human Services (“HHS”) recently released a final rule titled “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017” (“Final Rule”)[1] that sets...more

Williams Mullen

Affordable Care Act Compliance Update for 2016

Williams Mullen on

Affordable Care Act (ACA) reforms have become effective incrementally over the last six years. In 2016, most of the ACA changes are applicable. Employers that sponsor group health plans should ensure that they are in...more

McGuireWoods LLP

Healthcare Costs for the Average Family Have Risen Dramatically

McGuireWoods LLP on

According to consulting and actuarial firm Milliman’s “2015 Milliman Medical Index,” which measures the cost of healthcare for a typical American family of four receiving coverage from an employer-sponsored preferred provider...more

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