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Final Regulations Expand Use of Health Reimbursement Arrangements

On June 13, 2019, the U.S departments of Health and Human Services (“HHS”), Labor, and the Treasury (collectively, the “Departments”) pre-released final regulations that will expand the use of health reimbursement arrangement (“HRAs”). Beginning in January 2020, employers will be

Julie Mitchell, Esq. June 25, 2019

Federal Court Issues Injunction on Contraceptive Mandate Enforcement

On June 5, 2019, the United States District Court for the Northern District of Texas issued a permanent injunction against the federal government from enforcing the Affordable Care Act’s (“ACA”’s) contraceptive mandate and accompanying accommodation process against any members of

Julie Mitchell, Esq. June 21, 2019

HHS proposes revision of its ACA Section 1557 rule, projects $3.6 billion in savings over next five years

On May 24, 2019, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) issued a proposed rule to revise its 2016 rule regarding certain forms of discrimination under Section 1557 of the Affordable Care Act ("ACA").

Julie Mitchell, Esq. June 13, 2019

Who, What, and Now What? Business Associate HIPAA Obligations

It's likely you've seen post after post discussing the Office for Civil Right's ("OCR") recent guidance for Business Associates ("BA") listing scenarios when BA may be directly liable for breaches of electronic Protected Health Information ("ePHI"). This is not one

Peter Iverson, Esq. June 10, 2019
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