Employers are required to notify participants and beneficiaries who are Medicare Part D eligible individuals and the Centers for Medicare and Medicaid Services (“CMS”) of the creditable or non-creditable status of the group health plan prescription drug plan(s).

Changes to Medicare Part D Creditable Coverage Determination The Inflation Reduction Act of 2022 (“IRA”) made several changes that will affect the structure of the […]

Change Healthcare Data Breach HIPAA Considerations Earlier this year, Change Healthcare, a large health payment processing company, announced a massive data breach which compromised personal […]

This decision overturns long-standing precedent established in Chevron U.S.A. Inc., v. Natural Resources Defense Council, Inc. (“Chevron”) that required federal courts to defer to an executive agency’s reasonable interpretation of ambiguous statutory provisions the agency administers (often referred to as Chevron deference).

The Departments of Labor, the Treasury, and Health and Human Services (collectively, “the Departments”) recently issued the updated Annual Submission Instructions and User Manual to facilitate the Gag Clause Prohibition Compliance Attestation (“GCPCA”) for 2024.