The Stark Law generally prohibits physicians from referring Medicare and Medicaid patients to facilities in which they have an ownership interest. There used to be a “whole hospital exception” excluding entire hospitals (as contrasted to departments or parts of hospitals) from the prohibition. The …
Rip Van Winkle Health Care Reform Update
April 14, 2014 Leave a Comment
Have you been asleep for a while, like Rip Van Winkle, and just waking up to learn about health care reform? Or just not been interested in watching the minutiae of health care reform? Or have you just become responsible for health care reform compliance? We have plenty of posts about what you need to know, …
Looking Ahead to 2013: Coverage of Women’s Preventive Services
October 29, 2012 Leave a Comment
With 2013 right around the corner, one new requirement that will be in effect on January 1 for calendar-year non-grandfathered group health plans is the coverage of certain women’s preventive services without cost-sharing. The coverage requirement is effective for plan years beginning on or after August 1, …
IRS Updates Form 8928 for Self-Reporting of Excises Taxes Owed for PPACA Failures
February 6, 2012 1 Comment
The IRS recently updated Excise Tax Form 8928 and its Instructions. Employers and plan sponsors must use Form 8928 to report excises taxes due for failures to meet certain requirements of the Public Health Services Act, COBRA, HIPAA or HSA comparable contributions. The revised Form 8928 and Instructions now …
New Guidance on the Summary of Benefits and Coverage
September 7, 2011 Leave a Comment
Health care reform’s latest addition to the alphabet soup of plan participant notices is the SBC—the Summary of Benefits and Coverage. Not to be confused with the SPD or SMM, the SBC is a new, separate notice that both grandfathered and non-grandfathered group health plan sponsors must be ready to provide by …
Retaining Grandfathered Status
August 31, 2011 Leave a Comment
As many employers with grandfathered health plans prepare for 2012, they may be considering changes to their plans that could affect the plans’ grandfathered status. Rules regarding grandfathered status have been issued in piece-meal fashion since the enactment of health care reform and we thought it would be …