Comments on “Grandfathered” Plan Regulations

Although the interim final regulations implementing the “grandfather” provisions of PPACA that were released on June 17, 2010, provided some guidance on what types of changes to a grandfathered plan would result in loss of grandfathered status, many questions remain for plan sponsors currently trying to decide …

[Read more...]

Unanswered Questions for Employers and Health Plans

Despite all the guidance that has been issued on health care reform, there are still many unanswered questions.  Employers and health plans would welcome additional guidance on the following: For W-2 reporting of health care coverage, does the reporting apply to non-employees, such as retiree, surviving …

[Read more...]

The Sixty Day Rule: Reporting & Returning Overpayments Under PPACA

Among numerous changes to the Medicare and Medicaid Program Integrity Provisions, Section 6402 the Patient Protection and Affordable Care Act (“PPACA”) contains urgent requirements for reporting and returning overpayments. The new provision requires certain entities – including providers, suppliers, …

[Read more...]

Comments on Adult Child Coverage

We continue to receive questions from our clients about the scope of coverage for adult children.  Although the tax guidance defined child as any natural, adopted, step or foster child, the coverage guidance did not define the term. The issue is whether dependency or residency conditions are allowed for …

[Read more...]

New Statute Sheds Light on Three-Day Rule for Hospital Billing

On June 25, 2010, President Barack Obama signed into law the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010. Among other provisions, Section 102 of the legislation broadens the interpretation of what is known as the three-day rule, Medicare's policy for payment for …

[Read more...]

New Rules: Internal Claims and Appeals and External Review Process

The government published rules on July 23 implementing new internal claims and appeals and external review processes under health care reform. The rules, effective for plan or policy years beginning on or after September 23, address new requirements for state external review processes that apply mainly to fully …

[Read more...]