Additional Early Retiree Applications Approved

Earlier this month, HHS announced the approval of an additional 1,000 employers and unions whose medical plans have been certified to participate in the Early Retiree Reinsurance Program. As we mentioned in our September 2 post, HHS announced the first round of nearly 2,000 approvals in August. Going forward, the …

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RAC Medical Necessity Denials: Asking for What Is Fair

Last week we wrote about the impending medical necessity denials from Medicare’s Recovery Audit Contractors (RACs). If an inpatient admission was not medically necessary, we talked about the potential application of the limitation of liability defense. Even if that is not successful, another alternative argument …

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Preventive Care Requirements Revisited

Comments were due in mid-September regarding the interim final regulations on preventive care requirements. Under the preventive care requirements, non-grandfathered group health plans must provide first-dollar coverage for the following: Evidence-based items or services with a rating of A or B in the …

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RAC Medical Necessity Denials Are On Their Way

On August 6, 2010, CMS gave its approval to CGI, the Recovery Audit Contractor (RAC) for Region B, to review the medical necessity of inpatient admissions. Other RAC contractors followed suit shortly thereafter. One of the specific issues approved relates to the medical necessity of an inpatient admission for …

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Additional Guidance on Grandfathered Status

We’ve previously discussed grandfathered status in alerts and webcasts. Generally, employers that want to maintain grandfathered status are restricted in the changes that can be made to a health plan as it existed on March 23, 2010. The latest guidance, more FAQs, clarifies how some of the requirements to …

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W-2 Relief for 2011

We previously blogged about the new Form W-2 requirement under health care reform. Health care reform technically requires disclosure of the cost of coverage effective for 2011 Forms W-2. But the IRS just issued relief for reporting health care coverage in 2011 and will not impose penalties for failure to do …

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