As expected, the lawsuits have commenced following the enactment of the Arkansas legislation prohibiting pharmacy benefit managers (PBM’s) from owning or operating actual pharmacies within the state. Michigan has filed its...more
In the first month of the second Trump presidency, the administration has focused on several executive orders and policy changes that may have significant implications for employer health and welfare plans. In a sweeping...more
Historically, the U.S. Department of Justice has directed its efforts on combatting healthcare fraud by focusing on persons and companies who defraud or attempt to defraud federally funded healthcare programs, such as...more
Welcome to the Summer 2024 issue of “FCA Enforcement & Compliance Digest,” our quarterly newsletter in which we compile essential updates on False Claims Act (FCA) enforcement trends, litigation, agency guidance, and...more
Three Men Sentenced for $54 Million TRICARE Fraud Scheme - Three men were sentenced in connection with a $54 million bribery and kickback scheme involving TRICARE, a federal program that provides health insurance benefits...more
If you work for or represent group health plans or issuers of group health plans, it is important that you take a look at the contracts they have with health care providers before the end of 2023. The Internal Revenue Code...more
On October 18, 2022, the Department of Justice (DOJ) announced two settlements with CHC Holdings, LLC, an Oklahoma limited liability company doing business as Carter Healthcare (Carter), and two former senior corporate...more
There continues to be considerable and understandable confusion about the effects of Michigan’s new auto No-Fault insurance law, which the Legislature passed in June 2019. No area of the new law has created more confusion...more
Compliance is a key aspect of operating a successful pharmacy in the United States. This is true for pharmacies that bill federal healthcare benefit programs (i.e. Medicare, Medicaid, and Tricare) and private payors, and it...more
The package was sent to the President’s desk after undergoing technical changes to paid medical leave and public health emergency medical leave provisions that will limit costs for small businesses. Employers with 500...more
Right of First Refusal EO Revoked. Last week, President Trump issued an Executive Order revoking Executive Order 13495 issued by President Obama in January 2009. EO 13495 required that successor Federal service contractors...more
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
With the rise in health insurance costs and changing work demographics, employers nationwide are considering innovative benefit designs that are intended to not only contain costs but also provide employees greater...more
As LGBTQ rights have taken center stage in political and social issues, FordHarrison has been following ground-breaking litigation related to LGBTQ rights and providing updates. In the latest decision, a federal judge in...more
The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more
On September 16, 2015, the IRS finalized these ACA coverage reporting Forms and Instructions... We report here, with minimal analysis, changes that we recognized on first comparison to the 2015 Draft Forms and Instructions....more
Retirement Plans - IRS Issues Guidance on Benefit Suspension Voting under MPRA - As we have written in prior alerts, the Multiemployer Pension Reform Act of 2014 (MPRA) permits trustees of financially troubled...more
In a recent notice, the Internal Revenue Service has tempered prior guidance that closed the door on employer arrangements for paying the cost of individual health insurance for employees. The IRS still views these premium...more
Continuing its focus on so-called “premium reimbursement” or “employer payment plans”, the Internal Revenue Service (IRS) released IRS Notice 2015-17 on February 18, 2015. In this Notice, which was previewed and approved by...more
Some employers – particularly smaller ones – have assisted their employees to obtain health insurance by reimbursing them for the cost of insurance they purchase in the individual market. Does this practice satisfy the...more
Last week, HHS, along with the Department of Labor and the Treasury, provided long overdue guidance regarding the third category of supplemental “excepted benefits” as defined by Section 2791 of the Public Health Services...more
The new Republican Congress began its session with an attempt to narrow the Affordable Care Act’s (ACA) employer mandate by exempting certain veterans and their families from counting toward the number of employees at small...more
A federal district court has confirmed the position of the Office of Federal Contract Compliance Programs (OFCCP) finding that three hospitals providing medical services to U.S. government employees, and receiving payments...more