On November 14, 2013, President Obama announced a plan that would enable certain Americans with health coverage to keep their existing coverage for an additional year even if their existing coverage fails to meet the minimum standards established under the Affordable Care Act (“ACA”).
As we reported earlier this week, the U.S. Department of Health & Human Services (“HHS”) recently issued a letter concluding that HHS “does not consider [Qualified Health Plans (QHPs)], other programs related to the Federally-facilitated Marketplace, and other programs under Title I of the Affordable Care Act to be federal […]
HHS: Qualified Health Plans are NOT “Federal Health Care Programs” – Implications for Anti-Kickback, CMP, and Exclusion Analyses
In an October 30, 2013, letter to Representative Jim McDermott (D-WA), U.S. Department of Health and Human Services (HHS) Secretary Kathleen Sebelius, stated that HHS “does not consider [Qualified Health Plans (QHPs)], other programs related to the Federally-facilitated Marketplace, and other programs under Title I of the Affordable Care Act to […]
As announced last week, the Centers for Medicare & Medicaid Services (CMS) issued another round of FAQs related to the implementation of the Sunshine Act. Below is a list of the 20 new CMS FAQs organized by category with a link to the answer from CMS for each. Cooley’s CMS Sunshine FAQs trackers also have been […]
As President Obama responds to healthcare.gov’s glitches, many states continue to debate whether to expand the Medicaid program in their respective states. The Supreme Court’s decision on the Affordable Care Act (“ACA”) allows states to opt out of the ACA’s Medicaid expansion provisions. Many states have stated their Medicaid expansion plans definitively; however, not all […]
The Secretary of the U.S. Department of Health and Human Services (HHS), Kathleen Sebelius, recently announced partnerships with pharmacies to increase enrollment in the Health Insurance Marketplace, which is scheduled to open for enrollment on October 1, 2013. According to the announcement, these pharmacies will “take an active role in outreach and education to […]