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HTMLGovernment Issues New Rules for Religious Employers, But Health Plans, TPAs, and PBMs are still on the Hook to Provide Contraceptive Coverage
Bridgette A. Wiley; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
Legal Alert/Article
September 4, 2014, previously published on September 3, 2014
The Affordable Care Act (“ACA”) requires that non-grandfathered health plans make preventive care and screenings available to their members at no cost (i.e. no deductibles, coinsurance, or co-payments). The Department of Health and Human Services (“HHS”) determined that...

 

HTML340B Drug Pricing Program Interpretative Rule Survives (for Now)
Elizabeth S. Elson, Anil Shankar; Foley & Lardner LLP;
Legal Alert/Article
September 4, 2014, previously published on September 2, 2014
A federal court entered a new order, on August 27, 2014, in an ongoing dispute between the Health Resources and Services Administration (HRSA) and the Pharmaceutical Manufacturers of America (PhRMA) regarding HRSA’s issuance of regulations for the 340B Drug Pricing Program (the 340B Program)....

 

HTMLThe Increasingly Murky World of 340B: What’s Next?
Ellyn L. Sternfield; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
Legal Alert/Article
September 4, 2014, previously published on September 2, 2014
For the past 18 months, health care providers and the pharmaceutical industry have been hoping for some clarity regarding 340B Drug Discount Program operations. But things just keep getting murkier.

 

HTMLConsidering Sex-Specific Variation for Personalized Medicine
Antoinette F. Konski; Foley & Lardner LLP;
Legal Alert/Article
September 4, 2014, previously published on September 2, 2014
Personalized medicine may use devices and assays that identify sex-related differences. For example, a device or an assay may determine if a cancer patient harboring a particular genetic variance will or will not respond to a particular cancer therapy. In some instances, the prediction of clinical...

 

HTMLAspiring Medicinal Marijuana Business Owners in Illinois Should Understand and Plan for the Potential Tax Pitfalls
Mark Milton; Husch Blackwell LLP;
Legal Alert/Article
September 3, 2014, previously published on August 27, 2014
On September 8, 2014, the state of Illinois begins accepting applications for medicinal marijuana dispensary and cultivation center permits. Under the state’s Compassionate Use of Medical Cannabis Pilot Program Act, passed last year, Illinois will grant one cannabis cultivation permit for...

 

HTMLSeptember 22, 2014 Deadline for Business Associate Agreements
Margaret Young Levi; Wyatt, Tarrant & Combs, LLP;
Legal Alert/Article
September 2, 2014, previously published on August 22, 2014
The final HIPAA Omnibus Rule (Omnibus Rule), published in the Federal Register on January 25, 2013, substantially increased the privacy and security responsibilities of a “business associate” of a “covered entity”, as those terms are defined by the Health Insurance...

 

HTMLEnd of Year Planning and Compliance Deadlines for Health Plans
Bret Busacker, John Franklin Clark; Holland & Hart LLP;
Legal Alert/Article
September 2, 2014, previously published on August 29, 2014
Now that fall is in the air and school has started, we thought this would be a good time to summarize some of the key health and welfare benefit deadlines that are approaching this fall:

 

HTMLSettlement a Harbinger of Escalating Stark Law Exposure for Physician Compensation?
Rick L. Hindmand, Jane Pine Wood; McDonald Hopkins LLC;
Legal Alert/Article
September 2, 2014, previously published on August 29, 2014
A cardiology group practice recently agreed to pay $1.3 million to resolve allegations that it violated the Stark federal physician self-referral law and the False Claims Act by paying its physicians under a compensation formula that considered their referrals for nuclear and CT scans. On Aug. 4,...

 

HTMLThe Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for Assessable Payments under the Affordable Care Act’s Pay-or-Play Rules
Alden J. Bianchi; Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.;
Legal Alert/Article
September 2, 2014, previously published on August 25, 2014
The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health plan coverage (i.e., “play”) or...

 

HTMLHealthcare Reform in the U.S. Territories; Prepayment of Taxes for Puerto Rico Retirement Plans
Karen N. Brandon, Grace Huang Ristuccia; Ogletree, Deakins, Nash, Smoak & Stewart, P.C.;
Legal Alert/Article
September 1, 2014, previously published on August 28, 2014
The summer of 2014 has brought further guidance for health plan coverage in the U.S. territories and for retirement plan coverage in Puerto Rico. Issuers and employer sponsors of Puerto Rico group health plans and employer sponsors of Puerto Rico retirement plans should review their plans to ensure...

 


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