2020 Drug Coupon Rule Under Further Rulemaking
The U.S. Department of Health and Human Services (“HHS”) released final regulations relating to benefit and payment parameters for 2020. The regulations state that beginning […]
Reporting Primary Prescription Coverage Mandatory January 2020
The Centers for Medicare & Medicaid Services (“CMS”) has issued new guidance on Medicare Secondary Payer (“MSP”) reporting requirements in response to the SUPPORT for […]
DOL Expands FMLA Leave to Special Education Meetings
A recent opinion letter issued by the U.S. Department of Labor (“DOL”) confirmed that parents attending certain school meetings for the benefit of their children […]
What is a “Functional” Fiduciary?
ERISA’s Fiduciary Duties Understanding the nature of an ERISA benefit-plan-fiduciary is a big deal; naming fiduciaries and identifying “fiduciary-like” decisions is an even bigger one. […]
Final Regulations Expand Use of Health Reimbursement Arrangements
On June 13, 2019, the U.S departments of Health and Human Services (“HHS”), Labor, and the Treasury (collectively, the “Departments”) pre-released final regulations that will […]
Federal Court Issues Injunction on Contraceptive Mandate Enforcement
On June 5, 2019, the United States District Court for the Northern District of Texas issued a permanent injunction against the federal government from enforcing […]
Who, What, and Now What? Business Associate HIPAA Obligations
It’s likely you’ve seen post after post discussing the Office for Civil Right’s (“OCR”) recent guidance for Business Associates (“BA”) listing scenarios when BA may […]
$3 million settlement, HIPAA breach affects 300,000 individuals’ PHI
On May 6, 2019, the U.S. Department of Health and Human Services (“HHS”) announced a $3 million settlement with Touchstone Medical Imaging (“Touchstone”) for potential […]
DOL Releases Second Guidance on Recent AHP Litigation
In response to the recent litigation surrounding association health plans (“AHPs”), the Department of Labor (“DOL”) released its second guidance on May 13, 2019, regarding […]