Health Care Reform Dashboard

Health Care Reform Dashboard

Charting Developments with the
Affordable Care Act and Beyond

Enforcement

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01/11/2022

Temporary Enforcement Policy Addresses CAA’s Health Plan Service Provider Disclosure Requirements

Summary The U.S. Department of Labor (DOL) has issued a temporary enforcement policy to address frequently asked questions about the requirement for certain service providers to disclose direct and indirect compensation data to group health plan fiduciaries under the Consolidated Appropriations Act (2021) (CAA). The Upshot The CAA’s disclosure requirement applies to entities providing brokerage or consulting services [&hellip… Continue Reading »
10/06/2021

Keeping Up With No Surprises

Summary Two sets of rules were issued last month by federal agencies as part of the No Surprises Act. The Upshot The proposed rules come into play when an individual receives out-of-network care in at least one of the following situations: in an emergency, when an out-of-network provider furnishes services in connection with care provided [&hellip… Continue Reading »
08/12/2021

OCR’s HIPAA Resolution Agreements: the Year Thus Far

The Office of Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) has continued its enforcement of the privacy and security rules included in the Health Insurance Portability and Accountability Act of 1996 (HIPAA), announcing a number of settlements of alleged violations in the first seven months of 2021. This settlement [&hellip… Continue Reading »
04/18/2019

HIPAA Enforcement Outlook for 2019 and Beyond

After announcing that its HIPAA enforcement collections had reached a new high-water mark of $28.7 million in 2018, the Office of Civil Rights (OCR) of the U.S. Department of Health and Human Services has started this year quietly. Through the first few months of 2019, the OCR has published no resolution agreements and it is [&hellip… Continue Reading »
11/15/2017

IRS Prepares to Enforce ACA Employer Mandate

The IRS has announced its intent to begin enforcing the employer-shared responsibility provisions (otherwise known as the employer mandate or pay-or-play provisions) of the Affordable Care Act for the 2015 calendar year. The IRS also published a template letter that it will mail to any applicable large employer (ALE) if it determines the ALE owes [&hellip… Continue Reading »
12/28/2015

Further Guidance on ACA Market Reforms for Group Health Plans

Following up on the issuance of final regulations on various market reform provisions under the Affordable Care Act (ACA), the IRS has issued a notice with Questions and Answers that take a more detailed look at specific ACA issues. In particular, this notice addresses: Health reimbursement arrangements (HRAs). The guidance confirms that retiree-only HRAs may [&hellip… Continue Reading »
12/22/2015

Cadillac Tax Delayed, Made Deductible

In the first significant congressional modification of the Affordable Care Act (ACA) since its passage, the notorious “Cadillac tax” on high-cost employer health plans has been delayed two years, from 2018 to 2020.  The delay is included in the omnibus spending and tax extenders bills President Obama signed on December 22.  Delay of the Cadillac [&hellip… Continue Reading »
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