The Issue: On June 24, 2019, President Trump signed an executive order, which instructed the Department of Health and Human Services to publish rules requiring hospitals to publicly disclose their negotiated rates for services. On August 9, 2019, proposed rules were published by the Centers for Medicare and Medicaid Services (“CMS”). The Situation: The proposed …
On March 28, 2019, the Department of Labor (“DOL”) issued a lengthy and detailed Notice of Proposed Rulemaking (“NPRM”) to revise the regulations governing how employers should calculate “regular rate” under the Fair Labor Standards Act (“FLSA”). Upon release, the DOL set a deadline for public notice and comment of May 28, 2019. However, citing …
On March 28, 2019, a judge for the United States District Court for the District of Columbia ruled against the Department of Labor (DOL) by invalidating critical aspects of the new association health plan rule (the Rule). In its decision, the Court found the Rule to be an unreasonable interpretation of the Employee Retirement Income …
The Medicare Secondary Payer (MSP) rules impose regulations on group health plans that govern how plans interact with Medicare and Medicare-entitled plan participants. While complex, the rules are designed to spread costs between Medicare and group health plans that are considered primary payer to Medicare. Employer-sponsors of group health plans that are subject to the …
Group health plans are subject to an ever-changing environment of regulations surrounding compliance and notice obligations. Many of the requirements apply equally to both insured and self-funded arrangements, and the insurance carrier often ensures compliance with certain items. This checklist provides an overview of the obligations for self-funded group health plans. Employers sponsoring self-funded plans …