Clarification on Rescissions

As we mentioned recently, the agencies are issuing additional guidance in the form of Frequently Asked Questions. The most recent of these FAQs answer a few of the questions we had raised in an earlier post. Today’s post will discuss the guidance on rescissions. Plan sponsors and administrators will be happy to …

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Guidance on Non-Discrimination Rules for Insured Plans

Internal Revenue Code Section 105(h) describes non-discrimination rules that apply to self-funded group health plans. PPACA extends the Section 105(h) non-discrimination requirements to non-grandfathered fully-insured group health plans. Unfortunately, even though Section 105(h) was added to the Code in 1978, …

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FDA Announces New Drug Safety Reports: Declare Your Risk

FDA has issued a new Final Rule governing the safety reports required for drugs under clinical investigation. Among other changes, FDA seeks to limit the number of adverse reaction reports it receives and increase the usefulness of each report. But what does “evidence to suggest a causal relationship” …

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Additional ERRP Reimbursement Information Released

Since releasing its first list of plans that have been approved to participate in the Early Retiree Reinsurance Program (ERRP), HHS has published the following additional information on its website to help sponsors of approved plans understand how to next proceed: New Reimbursement Preparation Features Now …

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Colorado Opts Out of CRNA Physician Supervision Requirement, but Not Without a Challenge

Last week, Governor Bill Ritter announced that Colorado will become the 16th state to opt-out of a federal Medicare rule that requires physician supervision of certified registered nurse anesthetists (CRNAs) in hospitals. States have the authority to opt-out of the supervision requirement by notifying CMS in …

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Does Health Care Reform Require My Plan to Provide Documents in Multiple Languages?

There are two areas where plans may have to provide participant communications in non-English languages. Claims & Appeals Notices: First, for claims and appeals, plans must provide "culturally and linguistically appropriate" notices that inform enrollees of the internal and external appeals processes. To …

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