Articles and Blogs

On July 1, 2021, the Departments of Health and Human Services (“HHS”), Labor and Treasury and the Office of Personnel Management (collectively, the “Departments”) published a much anticipated interim final rule (“IFR”) implementing certain provisions of the No Surprises Act (the “Act”). While the IFR addresses some key aspects of the Act, it does... READ MORE

On November 12, 2020, the United States Department of Health and Human Services (“HHS”), Department of Labor and Department of the Treasury jointly published a final rule requiring health care payors to publicly disclose certain price and cost-sharing information (the “Final Rule”). The Final Rule, which HHS refers to as the “Transparency in Coverage”... READ MORE

Recently, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a favorable advisory opinion, Advisory Opinion 19-01, concerning a charitable pediatric clinic (the “Clinic”)’s arrangement under which the Clinic waives cost-sharing amounts for a small percentage of TRICARE and Medicare beneficiaries not covered by a state insurance program (the “Arrangement”). After... READ MORE