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Author Archives: Bose McKinney & Evans LLP
Proposed EEOC Rules Address Wellness Programs
Authored by John Westercamp On April 20, 2015, the Equal Employment Opportunity Commission (“EEOC”) published proposed regulations addressing wellness programs. The EEOC estimates that approximately 400,000-600,000 employers offer wellness programs which are regulated by the Americans with Disabilities Act (“ADA”). … Continue reading
Posted in Uncategorized
Tagged ACA, ADA, EEOC, HIPAA, Wellness programs
Transitional Reinsurance Reporting Deadline Extended
The Center for Medicare & Medicaid Services (“CMS”) granted a last minute extension for filing the Annual Enrollment and Contributions Submission Form as part of the Affordable Care Act’s Transitional Reinsurance Program. On Friday, November 14th, CMS announced that the … Continue reading
Skinny Plans Do Not Provide Minimum Value Coverage
In an announcement made November 4th, the Internal Revenue Service (IRS) issued guidance indicating that “skinny plans” will not help employers avoid all of the “play or pay” penalties under the Affordable Care Act. In Notice 2014-69, the IRS states … Continue reading
Posted in Patient Protection and Affordable Care Act
Tagged Affordable Care Act, IRS, Skinny Plans
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Delay of HPID Regulations Announced by CMS
With the November 5th deadline looming, the Centers for Medicare & Medicaid Services (“CMS”) announced that effective October 31, 2014, the enforcement of the regulations pertaining to the use of the Health Plan Identifier (“HPID”) is delayed until further notice. … Continue reading
IRS Releases Draft Versions of Forms for Health Information Reporting by Employers
The IRS released final regulations on March 5, 2014, outlining the employer reporting requirements that will take effect for the 2015 taxable year. While the final regulations specified the type of information that will need to be reported, the actual … Continue reading
Supreme Court Rules ACA Contraception Mandate Violates Religious Freedom Restoration Act in Hobby Lobby Case
In an opinion delivered by Justice Alito, the Supreme Court of the United States ruled on June 30, 2014, that closely held for-profit corporations can deny contraceptive coverage when citing religious beliefs. The owners of Conestoga, Hobby Lobby and Mardel, … Continue reading
Deadline for Amending HIPAA Business Associate Agreements is September 22, 2014
Last year, the U.S. Department of Health and Human Services (“HHS”) published the long awaited Omnibus Final Rule which made a number of modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules (“HIPAA Final Rule”). Business Associate Agreements … Continue reading
Annual Report to Congress on Breaches of Unsecured Protected Health Information
Recently, the Secretary of Health and Human Services submitted to Congress an annual report containing the number and nature of breaches of unsecured protected health information reported to the Office of Civil Rights (“OCR”) as required by the Health Insurance … Continue reading
