CMS to Implement Fingerprint-Based Background Checks for High-Risk Providers and Suppliers in 2014

Fingerprint-based background checks intended to “detect bad actors” enrolled or attempting to enroll in federal health programs

This post was authored by Elizabeth Carder-Thompson and Debra McCurdy.

More than three years after publication of final regulations to implement Affordable Care Act (ACA) provisions that strengthen provider and supplier enrollment screening provisions under federal health care programs, the Centers for Medicare & Medicaid Services (CMS) has selected a Fingerprint-Based Background Check Contractor (FBBC) and intends to phase in fingerprint-based background checks beginning in 2014.


By way of background, CMS published a final rule on February 2, 2011 pursuant to Section 640 of the ACA, which required the Department of Health and Human Services to establish procedures for screening providers and suppliers participating in federal health care programs (specifically, Medicare, Medicaid, and the Children’s Health Insurance Program).  Among other things, the final rule applies various screening tools, including unannounced site visits, background checks, and fingerprinting, based on the level of risk associated with different provider and supplier types.  CMS established three levels of risk – limited, moderate, and high – and every provider and supplier category is assigned to one of these three levels.  Individuals who maintain a 5 percent or greater direct or indirect ownership interest in a provider or supplier in the high risk category -- including newly-enrolling home health agencies (HHAs) and newly-enrolling durable medical equipment, orthotics, prosthetics, and supplies (DMEPOS) suppliers -- are subject to a fingerprint-based criminal history report check of the Federal Bureau of Investigations (FBI) Integrated Automated Fingerprint Identification System. 


While the final rule was effective March 25, 2011, as mandated by the ACA, CMS delayed the effective date of the fingerprint-based criminal history record check provision until after additional subregulatory guidance was issued.   CMS awarded a $4.19 million FBBC contract to Accurate Biometrics, Inc. in March 2014, a significant step in the implementation process.  Following this award, CMS issued a provider update announcing that it intends to phase in the fingerprint-based background check implementation beginning in 2014Not all providers and suppliers in the "high" level of risk category will initially be a part of the fingerprint-based background check requirement, but eventually the fingerprint-based background check will be completed on all individuals with a 5 percent or greater ownership interest in a provider or supplier that falls under the high-risk category.


Providers and suppliers subject to the fingerprint requirements will receive a notification letter from their Medicare Administrative Contractor (MAC), and applicable individuals will have 30 days from the date of the notification letter to be fingerprinted at one of at least three locations identified by the FBBC (individuals will incur the cost of having their fingerprints taken). After fingerprinting is complete, the fingerprints will be forwarded to the FBI, which will compile the background history and share results with the FBBC within 24 hours of receipt. The FBBC will assess the data and provide a "fitness recommendation" to CMS indicating whether the criminal history record information contains enrollment violations or otherwise fails to meet requirements or guidelines established by CMS for enrollment of a Medicare provider or supplier; CMS will then make the final determination about the provider or supplier. CMS will notify providers and suppliers if the assessment of the fingerprint-based background check results in the denial of an enrollment application or revocation of existing Medicare billing privileges. The CMS guidance also provides information on standards for securing the data under the review process.


This announcement marks the latest steps in seemingly ever-escalating CMS efforts to clamp down on fraud and abuse in the Medicare and Medicaid programs. While the initial targets of the fingerprint-based background requirements are new DMEPOS suppliers and HHAs, the policy also will apply to those who are elevated to the high risk category in accordance with enrollment screening regulations, which could include providers/suppliers coming back into the Medicare fee-for-service program after a moratorium is lifted, or providers which have been subject to a payment suspension, exclusion, or revocation. It is likely that some "owners" of entities, such principals of investment firms with financial interests in providers and suppliers, will balk at the whole idea of being fingerprinted. Moreover, the pending fingerprint process will doubtless provide even more opportunities for administrative missteps, and erroneous and time-consuming supplier/provider number revocations.

April Congressional Hearings

Recent Congressional hearings on health policy issues include the following:

  • House Energy and Commerce Committee hearings on the “Helping Families in Mental Health Crisis Act”; the FDA’s proposed changes to generic drug labeling; and legislation intended to improve predictability and transparency in Drug Enforcement Agency and FDA regulation (H.R. 4299, H.R. 4069, and H.R. 4250).
  • House Ways and Means Health Subcommittee hearing on final Treasury Department regulations implementing the employer mandate and employer information reporting requirement provisions of the ACA..

In addition, on April 9, 2014, the Senate Health, Education, Labor and Pensions Committee is holding a hearing on “Addressing Primary Care Access and Workforce Challenges: Voices from the Field.”

CMS Extends Deadline for Individuals to Enroll in Health Insurance through Exchanges

CMS has extended the Affordable Care Act (ACA) insurance enrollment period for individuals (1) who have had difficulty signing up for a health insurance plan through an Affordable Insurance Exchange by March 31, 2014, or (2) who have not signed up by March 31 due to a wide range of circumstances. First, in a March 26, 2014 document, CMS announces it has established a “special enrollment period” for individuals who cannot complete the enrollment process “despite their best efforts” for reasons such as “high consumer traffic across various consumer enrollment channels…leading up to the March 31 deadline.” Provided that consumers who were “in line” pay their first month’s premium by the deadline set by their chosen insurance company, CMS anticipates that enrollments made in an unspecified time period after March 31 will have a May 1 coverage effective date. Consumers who receive a special enrollment period for being “in line” and select new coverage within the timeframes outlined in the guidance will be able to claim a hardship exemption from the shared responsibility payment for the months prior to the effective date of their coverage.

CMS also has compiled all of the categories CMS has identified to date that warrant special enrollment periods after the end of the March 31 open enrollment period, including situations involving: certain exceptional circumstances; misinformation, misrepresentation, or inaction by entities providing formal enrollment assistance; enrollment error; system errors related to immigration status; display errors on Marketplace website; Medicaid/CHIP - Marketplace transfer problems; error messages; unresolved casework; victims of domestic abuse; or other system errors that hindered enrollment completion.

Obama Administration Continues to Update ACA Insurance Exchange and Health Plan Regulations

The Administration has issued numerous regulations recently that make additional changes to operational policies, payment provisions, and other standards applicable to health plans and Health Insurance Exchanges (also called Marketplaces) under the Affordable Care Act (ACA). Highlights include the following:

  • On March 21, 2014, the Department of Health and Human Services (HHS) published a proposed rule to update ACA Exchange and insurance market standards beginning in 2015. Among other things, HHS proposes standards related to: consumer notification of insurance product discontinuation and renewal; Qualified Health Plan (QHP) quality data reporting to support quality ratings; non-discrimination standards; employee choice in the Small Business Health Options Program (SHOP); enforcement remedies; HHS’s allocation of reinsurance contributions; the ceiling on allowable administrative expenses in risk corridor calculation; eligibility standards for an exemption from the shared responsibility payment; the imposition of civil money penalties for providing false or fraudulent information to the Exchange and for improperly using or disclosing information; updated standards for “Navigators” and other consumer assistance programs; amendments to Exchange appeals, coverage enrollment, and coverage termination standards; and adjustments to the medical loss ratio program standards. Comments will be accepted until April 21, 2014.
  • HHS published a final rule on March 11, 2014 setting forth key payment and policy provisions for health insurers participating in Exchanges in 2015. Among many other things, the lengthy rule establishes standards for: premium stabilization programs (risk adjustment, reinsurance, and risk corridors programs); the open enrollment period for 2015 (November 15, 2014 through February 15, 2015); cost sharing limitations; consumer protections; financial oversight; privacy and security of personally identifiable information in the Exchange; and SHOP functions. Of note, the rule provides a state-level adjustment in the risk corridors formula to account for a transition policy announced on November 14, 2013 that allowed certain insurers in the small group and individual insurance markets to renew policies that did not comply with all 2014 insurance market rules, if permitted by their state (an extension of this transition policy is discussed in a separate post). According to HHS, this risk corridor adjustment is designed to offset unanticipated higher average claims costs that issuers of plans complying with market rules could experience as a result of the transition policy. The regulations are effective on May 12, 2014.
  • HHS has published a final rule establishing the Basic Health Program (BHP), which provides states with the flexibility to establish a health benefits coverage program for certain low-income individuals who are not eligible for Medicaid and who would otherwise be eligible to purchase coverage through the Exchange. Specifically, the rule establishes: (1) the requirements for state administration of the BHP consistent with its certified “Blueprint”; (2) eligibility and enrollment requirements; (3) minimum benefits requirements; (4) the availability of federal funding; (5) the purposes for which states can use federal funding; (6) enrollee financial participation parameters; and (7) requirements for administration and oversight of BHP funds. The rule is effective January 1, 2015.  HHS set forth the specific methods for calculating and providing payment to states in a separate final rule, also published on March 12.
  • The Internal Revenue Service (IRS) published final regulations implementing an ACA provision specifying that certain health insurance issuers, employers, and others that provide minimum essential coverage to individuals must report to the IRS information about the type and period of coverage and provide a statement to individuals. Among other things, the regulations address coverage subject to reporting, entities required to report, information required to be reported, and the time and manner of reporting. The IRS also published related regulations regarding the specific reporting requirements applicable to certain large employers (generally those with at least 50 full-time employees, including full-time equivalent employees).  Both regulations are effective on March 10, 2014.
  • The Administration has published a request for information regarding an ACA provision specifying that a “group health plan and a health insurance issuer offering group or individual health insurance coverage shall not discriminate with respect to participation under the plan or coverage against any health care provider who is acting within the scope of that provider’s license or certification under applicable state law.” The notice, which was jointly published by the Centers for Medicare & Medicaid Services (CMS), the IRS, and the Employee Benefits Security Administration, solicits feedback on all aspects of the interpretation of this provision, including comments on access, costs, other federal and state laws, and feasibility. Comments will be accepted until June 10, 2014.

CMS Releases Subregulatory Guidance on ACA Insurance Coverage, Exchange Issues

Recent CMS subregulatory guidance and related announcements regarding ACA insurance coverage and insurance exchange issues include the following:

  • On March 14, 2014, CMS released its final “2015 Letter to Issuers in the Federally-facilitated Marketplaces,” which provides operational and technical guidance to issuers seeking to offer qualified health plans (QHPs) in a federally-facilitated Marketplace and/or SHOP.
  • CMS is extending its previously-announced “hardship” exemption and allowing consumers in the individual and small group markets to renew policies that do not comply with ACA QHP standards through October 1, 2016 (if the policies are still offered and if permitted by applicable state authorities). CMS will consider the impact of this two-year extension of the “transitional policy” in assessing whether an additional one-year extension is appropriate. 
  • An HHS blog post announced that beginning in 2015, if an insurance company offers health coverage to opposite-sex spouses, it cannot choose to deny that coverage to same-sex spouses.
  • CMS is allowing enrollees in the federal Pre-Existing Condition Insurance Plan (PCIP) who have not yet enrolled in new health insurance coverage through an Exchange plan to purchase an additional month of PCIP coverage, through April 30, 2014.

CMS Rule Requires Qualified Health Plans to Accept Certain Third-Party Premium Payments

Today CMS published an interim final rule with comment period that requires qualified health plan (QHP) issuers to accept premium and cost-sharing payments made on behalf of enrollees by the Ryan White HIV/AIDS Program, Indian tribes and organizations, and other federal and state government programs that provide premium and cost sharing support. This rulemaking was prompted by CMS concerns that some QHP issuers continue to reject Ryan White cost-sharing payments despite previous CMS guidance, which is resulting in beneficiary access problems. This standard applies to all individual market QHPs, including Stand Alone Dental Plans (SADP), regardless of whether they are offered through a federal or state Exchange or outside of the Exchanges. On the other hand, CMS specifies in the preamble that the rule would not prevent QHPs and SADPs from rejecting premium and cost sharing payments made by other third parties, including hospitals, other healthcare providers, and other commercial entities. CMS continues to encourage QHPs and SADPs to reject such payments, given CMS’s concern that they “could skew the insurance risk pool and create an unlevel competitive field in the insurance market.” The interim final rule is effective on March 14, 2014; comments will be accepted on the rule until May 13, 2014.

"Medicare Care Choices Model" to Allow Certain Hospice Patients to Seek Curative Care

CMS has launched a new Medicare Care Choices Model (Model) to allow Medicare beneficiaries with certain medical conditions to receive palliative care services from selected hospice providers without forgoing curative care services. The initiative will allow CMS to study whether access to curative services results in improved quality of care and patient and family satisfaction, and whether there are any effects on use of curative services and the Medicare hospice benefit.

The Model is expected to cover at least 30,000 Medicare and Medicare/Medicaid dual eligible beneficiaries with advanced cancers, chronic obstructive pulmonary disease, congestive heart failure, and HIV/AIDS over a three-year period. CMS will select at least 30 rural and urban hospices to participate in the program, with the hospices to be paid a $400 per-beneficiary/per-month fee to furnish services available under the Medicare hospice benefit for routine home care and inpatient respite levels of care that cannot be separately billed under Medicare Parts A, B, and D. Such services must be available 24/7, 365 calendar days per year. Providers and suppliers furnishing curative services to beneficiaries participating in the Model will be able to continue to bill Medicare for reasonable and necessary services.

Hospices interested in participating in the Model must apply by June 19, 2014.  Application materials and additional information, including hospice eligibility criteria, are available here.

Obama Administration Cites Record-Breaking Health Fraud Recoveries under Joint DOJ-HHS Program

According to the latest Health Care Fraud and Abuse Control Program (HCFAC) Annual Report, federal health care fraud prevention and enforcement efforts resulted in the recovery of a record $4.3 billion in FY 2013, up from $4.2 billion in FY 2012. In announcing detailed enforcement achievements, the Administration cites new ACA authorities – including enhanced provider screening requirements, limited enrollment moratoria, and authority to suspend Medicare payments during pending investigations -- that have improved the government’s ability to clamp down on health care fraud. The report also notes the successes of coordinated Department of Justice (DOJ) and HHS efforts such as the Health Care Fraud Prevention & Enforcement Action Team (HEAT) and interagency Medicare Fraud Strike Force teams.

Obama Administration Issues ACA Health Coverage Waiting Period Regulations

On February 24, 2014, the Departments of HHS, Labor, and Treasury published final regulations that generally bar employer-sponsored group health plans and group health insurance issuers from imposing a health coverage waiting period of more than 90 days after an employee is otherwise eligible for coverage. Other conditions for eligibility are generally permissible, such as being in an eligible job classification, achieving job-related licensure requirements specified in the plan's terms, or satisfying a reasonable and bona fide employment-based orientation period. Note that the rules do not require coverage be offered to any particular individual or class of individuals, nor do they require any waiting period to be imposed). The 90-day waiting period limitation provisions apply to group health plans and group health insurance issuers for plan years beginning on or after January 1, 2015.  A companion proposed rule would limit to one month the length of a bona fide employment-based orientation period for purposes of the waiting period rules. Comments on the proposed regulations will be accepted until April 25, 2014.

CMS to Allow Retroactive ACA Insurance Subsidies for Certain Non-Marketplace Plans

CMS has announced that in light of persistent problems individuals have had enrolling in qualified health plans (QHPs) through some state-run Marketplaces, it will now allow individuals to access premium tax credits and cost-sharing reductions on a retroactive basis in certain circumstances. Specifically, in guidance dated February 27, 2014, CMS states that if a Marketplace was unable to provide timely eligibility determinations during the initial open enrollment period for the 2014 coverage year, it may be considered an “exceptional circumstance” for individuals who were unable to enroll in a QHP as a result.  In such cases, CMS will make available advance payments of the premium tax credit and advance payments of cost-sharing reductions on a retroactive basis once the Marketplace has determined that the individual is eligible for such assistance and the individual has enrolled in a QHP through the Marketplace. Notably, CMS also provides an individual in this exceptional circumstance who is enrolled in a QHP offered outside of the Marketplace when he or she receives a determination of eligibility will be treated as having been enrolled through the Marketplace since the initial enrollment date.

CMS Issues Draft Guidance for Qualified Health Plan Issuers for 2015

On February 4, 2014, CMS released draft operational and technical guidance to health insurance issuers that seek to offer Qualified Health Plans (QHPs) in a Federally-Facilitated Marketplace (FFM) and/or a Federally-Facilitated Small Business Health Options Program (FF-SHOP) in 2015 and beyond (unless superseded in future years by subsequent regulations or guidance). Among many other things, the draft guidance addresses: the certification process and standards for QHPs (including the rate review process and network adequacy standards); QHP performance and oversight policies; and various consumer protection requirements. CMS will accept comments on the policies set forth in the guidance (to the extent that they are not the subject of separate rulemaking processes) until February 25. 2014.

CMS Seeks New Participants for Bundled Payments for Care Improvement Initiative

On February 14, 2014, CMS published a notice announcing an open period for additional organizations to be considered for participation in Models 2, 3, and 4 of the Bundled Payments for Care Improvement initiative. The three models are described as follows:

  • Model 2--Retrospective bundled payment models for hospitals, physicians, and post-acute providers for an episode of care consisting of an inpatient hospital stay followed by post-acute care.
  • Model 3--Retrospective bundled payment models for post-acute care where the episode does not include the acute inpatient hospital stay.
  • Model 4--Prospectively administered bundled payment models for the acute inpatient hospital stay and related readmissions.

Interested parties must submit the requisite forms by April 18, 2014. 

IRS Issues ACA Employer "Shared Responsibility" Guidance; Delays Compliance Deadlines for Certain Employers

This post was written by Allison Warden Sizemore and Debra McCurdy.

On February 12, 2014, the Internal Revenue Service (IRS) published final regulations modifying the timeline under which certain employers will be required to make “shared responsibility” payments if they do not provide qualified health insurance for their full-time employees and dependents pursuant to the Affordable Care Act (ACA). Specifically, under a new “transition relief” policy, the IRS is delaying the shared responsibility payment obligation for employers with 50 to 99 full-time equivalent employees from 2015 until 2016, although such employers will have to submit reports regarding their employees’ coverage in 2015. In order to qualify for transition relief, employers must certify that they have not laid-off workers to drop below the 100 employee threshold and must not eliminate or materially reduce their coverage offerings. The regulations also provide that employers subject to the employer responsibility provisions in 2015 (i.e., employers with 100 or more full-time equivalent employees) must offer coverage to at least 70% of full-time employees to avoid a penalty, rather than 95% (the 95% threshold will take effect in 2016). The regulations also clarify whether certain types of employees or employees in certain occupations are considered full-time (such as volunteer firefighters and emergency responders, educational employees, and seasonal workers) and clarify other open questions from the prior proposed regulations.

GAO Urges CMS to Finalize ACA Medicaid Drug Pricing Reforms

The GAO recently issued a report on CMS efforts to implement Medicaid drug pricing reforms mandated by the Affordable Care Act (ACA). Specifically, the report discusses CMS development of the National Average Drug Acquisition Cost (NADAC) benchmark of retail pharmacy acquisition costs, and how NADAC amounts compare to ACA-based federal upper limits (FULs). Based on first quarter 2013 data, GAO found that draft FUL amounts calculated under the ACA formula were about 1.4% lower than the total NADAC amount in aggregate for 1,035 outpatient drugs. On the other hand, ACA-based FULs for individual drugs ranged from 96% lower than to 404% higher than the NADACs for the same drugs. The GAO also found large differences between the total ACA-based FUL amount and the total NADAC amount for generic and for branded generic versions. According to the GAO, total ACA-based FUL amount for the generic versions was 19% higher than the total NADAC amount, but for the branded generic versions the ACA FUL amount was 26% lower than the NADAC.

The GAO concluded that CMS is close to having a formula under which FULs would better reflect pharmacy acquisition costs, but it observes that CMS continues to apply FULs that were calculated more than four years ago. The GAO also observed that the relationship between ACA-based FULs and NADACs may be affected by factors such as rebates and discounts that are not reflected on pharmacy invoices, which will necessitate continued CMS monitoring. The GAO therefore recommended that CMS (1) expeditiously implement the ACA-based FUL formula and (2) monitor the relationship between the ACA-based FULs and the NADACs on an ongoing basis. HHS concurred with these recommendations; noting that it intends to finalize the ACA Medicaid FULs for multiple source drugs in July 2014 (CMS indicated to GAO that the agency was still considering how the ACA-based FULs would apply to branded generic versions in the final rule).

CMS Considering Innovative Episode-Based Payment Models for Outpatient Specialty Practitioner Services

CMS is requesting public comments on ways to structure new models for delivering and paying for Medicare outpatient specialty practitioner services. The first broad model CMS is considering is a procedural episode-based payment model, where the episode of care would be defined around an outpatient surgical or interventional procedure such as colonoscopy or cardiac catheterization. Payment under this model would include all related services furnished during the episode, such as practitioners’ services (e.g., anesthesia, pathology, and/or radiology), diagnostic tests, Medicare-covered prescription drugs, and if applicable, ambulatory surgical center or hospital outpatient department facility payments.

A second model being considered is described as a complex and chronic disease management episode-based payment model. In this case, the episode would be defined as a prolonged period of time for management of the condition by a specialist practitioner, and the bundle could contain the same comprehensive services as contemplated under the procedural interventional model. In both models, CMS is concentrating on care by specialist practitioners other than medical oncologists, since a potential oncology model is being developed on a separate track.

CMS is exploring these options under its Affordable Care Act authority to test innovative payment and service delivery models that have the potential to reduce program expenditures while preserving or enhancing the quality of care for Medicare, Medicaid and Children’s Health Insurance Program beneficiaries. 

** Note that CMS has extended the comment period from March 13, 2014 until April 10, 2014.

Congressional Health Policy Hearings

Recent Congressional hearings have addressed a number of health policy issues, including the following:

Advisory Panel Recommends Access Standards for Medical Diagnostic Equipment

The Access Board's Medical Diagnostic Equipment Accessibility Standards Advisory Committee has issued its final report on “Advancing Equal Access to Diagnostic Services: Recommendations on Standards for the Design of Medical Diagnostic Equipment for Adults with Disabilities.” The report includes detailed recommendations on standards for access to equipment such as examination tables and chairs, weight scales, and diagnostic equipment. Among other things, the report address transfer access, armrests, lift compatibility, and other features for accessibility. The standards, which are being developed as directed under the ACA, still must be approved by the full Access Board.

CMS Proposes 2015 Funding Methodology for ACA Basic Health Program

CMS has published its proposed methodology and data sources necessary to determine federal payment amounts made to states that elect to establish a Basic Health Program (BHP) under the Affordable Care Act (ACA) to offer health benefits coverage to low-income individuals otherwise eligible to purchase coverage through Affordable Insurance Exchanges. The BHP, which will be available for states to implement effective January 1, 2015, is intended to make affordable health benefits coverage available for individuals under age 65 with household incomes between 133% and 200% of the federal poverty line who are not otherwise eligible for Medicaid, the Children’s Health Insurance Program, or affordable employer sponsored coverage. Comments will be accepted until January 22, 2014.

CMS Issues Formally Updates 2014 Health Exchange Enrollment Deadlines

CMS has published an interim final rule with comment period that sets a December 23, 2013 deadline for individuals to select a qualified health plan through an Exchange for an effective coverage date of January 1, 2014, to conform to a previously-announced policy. The prior regulation imposed a December 15, 2013 deadline. State Exchanges may select a different deadline. The rule pertains to the individual market and Small Business Health Options Program in both the Federally-facilitated Exchanges and State Exchanges; it does not change the plan selection or premium payment dates for coverage offered outside of the Exchanges.

Hardship Exemption for Individuals with Cancelled Insurance Policies

The Obama Administration has announced a “hardship” exemption for certain individuals who have been notified that their individual health insurance policies have been cancelled and will not be renewed. In such cases, if the individual believes that the plan options available in the ACA Health Insurance Marketplace/Exchange are more expensive then the cancelled health insurance policy, the individual will be eligible for a hardship exemption from the “shared responsibility” payment and will be able to enroll in catastrophic coverage, if available (catastrophic coverage plans previously were limited to individuals under age 30 meeting certain conditions).

Older Entries

December 10, 2013 — CMS Updates Medicare Physician Fee Schedule, Other Part B Policies for CY 2014

December 10, 2013 — CMS Proposed Rule on ACA Benefit and Payment Parameters for 2015

December 10, 2013 — Congressional Hearings Examine ACA Insurance Developments and Other Health Policies

December 3, 2013 — House Approves "Keep Your Health Plan Act"

November 25, 2013 — Congressional Panels Continue Focus on ACA Insurance Enrollment, Security, and Cost Issues, and Other Health Policy Topics

November 25, 2013 — CMS Seeks Input on Quality Ratings for ACA Exchange Plans

November 25, 2013 — CMS Releases Standard Consumer Notices under ACA Grandfathering/Transitional Policy

November 14, 2013 — HHS Allows Grandfathering of Certain Insurance Policies Cancelled under ACA Rules

November 14, 2013 — Obama Administration Releases Initial Health Insurance Marketplace Enrollment Numbers

November 14, 2013 — House Schedules Vote on "Keep Your Health Plan Act"

November 14, 2013 — Congressional Hearings Focus on Enrollment, Other Policy Issues

November 14, 2013 — HHS Corrects March 2013 ACA Benefit, Payment Parameter Rules

November 11, 2013 — CMS Announces Inflation Update to "Sunshine Act" Reporting Thresholds for 2014

October 30, 2013 — Obama Administration Aligns Health Exchange Enrollment Deadline and "Shared Responsibility" Penalty Trigger

October 30, 2013 — Congressional Hearings Focus on Rocky Rollout

October 30, 2013 — CMS Finalizes ACA Exchange Program Integrity & Financial Oversight Standards

October 30, 2013 — Nominees Invited for PCORI Physician Representative

October 10, 2013 — ACA Health Insurance Marketplace Opens for Business to Mixed Reviews

October 10, 2013 — HHS Proposes ACA Basic Health Program Regulations

October 10, 2013 — CMS Proposes Rules for Medicare FQHC PPS, CLIA Amendments

October 10, 2013 — Obama Administration Warns Consumers about Potential "Obamacare" Fraud

September 17, 2013 — CMS Finalizes ACA Exchange/Qualified Health Plan Financial Integrity and Oversight Standards

September 17, 2013 — House Approves Bill to Require Verification of ACA Individual Subsidy Eligibility

September 17, 2013 — IRS Finalizes ACA Individual "Shared Responsibility" Payment Requirements

September 16, 2013 — CMS Releases ACA Medicaid DSH Funding Final Rule

September 16, 2013 — OIG Urges CMS Action on Medicaid Drug Pricing Changes in Preparation of ACA Enrollment Expansion

September 16, 2013 — Upcoming House Hearings on ACA Implementation (Sept. 18 & 19)

September 16, 2013 — Congressional Health Policy Hearings

September 10, 2013 — No CMS DME Face-to-Face Rule Enforcement Before 2014

August 27, 2013 — HHS Seeks Comments on ACA Provision Preventing Discrimination in Certain Health Programs, Activities

July 29, 2013 — CMS Announces First Temporary Moratoria on HHA, Ambulance Supplier Enrollment in High-Risk Areas under ACA Authority

July 29, 2013 — House Approves Legislation to Amend ACA to Delay Insurance Mandates

July 29, 2013 — CMS Finalizes ACA Health Insurance Exchange "Navigator" Standards

July 29, 2013 — CMS Issues Final Medicaid Eligibility/Enrollment Rule under the ACA

July 29, 2013 — Obama Administration Finalizes Revised ACA Contraceptive Coverage Requirements

July 29, 2013 — July Health Policy Hearings

July 29, 2013 — In Advance of Sunshine Act Reporting, CMS Releases Physician & Industry Resources

July 5, 2013 — Medicare Home Health PPS Rates to Drop under Proposed CY 2014 Rule

July 3, 2013 — Obama Administration Announces Delay in Employer ACA "Shared Responsibility" Payments, Reporting Requirements until 2015

June 27, 2013 — HHS Releases Final ACA Exchange Rule on "Shared Responsibility" Payments

June 27, 2013 — CMS Proposes ACA Exchange/Qualified Health Plan Financial Integrity and Oversight Standards

June 27, 2013 — Obama Administration Credits ACA Rules with $3.9 Billion in Insurance Premium Savings, Rebates for 2012

June 27, 2013 — CMS Gears Up for ACA Health Insurance Marketplace/Exchange Launch

June 27, 2013 — GAO Reviews Status of ACA Insurance Exchange Development

June 27, 2013 — Health Policy Hearings

June 11, 2013 — CMS Sets Provider Payment Rates Under the ACA Pre-Existing Condition Insurance Plan Program

June 11, 2013 — CMS Publishes Final ACA Small Business Health Option Program (SHOP) Rule

June 11, 2013 — CMS Finalizes Medicare Advantage/Part D Plan Medical Loss Ratio Rules

June 11, 2013 — CMS Seeks Additional Applicants for Bundled Payments for Care Improvement Program

June 11, 2013 — State DSH Allotments Methodology

June 11, 2013 — DOL Releases Insurance Exchange Notice Guidance and Model Notices

June 11, 2013 — Medicare Trustees Forecast Longer Medicare Solvency

June 11, 2013 — Obama Administration Issues Final ACA Wellness Program Rules

June 11, 2013 — GAO Assesses State Efforts to Establish ACA Insurance Exchanges

June 11, 2013 — Health Policy Hearings

June 11, 2013 — House Approves ACA Repeal Legislation

June 6, 2013 — CMS Hosts Calls on Medicare Shared Savings Program Application Process

June 5, 2013 — HHS-Operated Risk Adjustment Data Validation Stakeholder Meeting (June 25)

May 14, 2013 — CMS Proposes Medicare IPPS and LTCH PPS Rates/Policies for FY 2014

May 13, 2013 — IRS Proposes Regulations to Implement Certain ACA Insurance Premium Tax Credit, Medical Loss Ratio Provisions

May 13, 2013 — CMS Notice Prepares for Termination of Early Retiree Reinsurance Program

May 10, 2013 — Congressional Health Policy Hearings & Markups

May 8, 2013 — CMS Actuary Determines No IPAB Cuts Needed in 2015

May 3, 2013 — CMS Sunshine Act Update: Covered Teaching Hospitals Listing, Industry Efforts, CMS Provider Call

April 15, 2013 — CMS Issues Final Rule on Federal Funding for Medicaid Expansion under the ACA

April 15, 2013 — IRS Proposes Hospital Community Health Needs Assessment Regulations

April 15, 2013 — CMS Letter to Issuers on Federally-Facilitated and State Partnership Exchanges

April 15, 2013 — April Congressional Health Policy Hearings & Markups

April 15, 2013 — HRSA Rule Transitions HIPDB to NPDB

April 15, 2013 — CMS Proposes Rules for Health Insurance Exchange "Navigators"

March 28, 2013 — Administration Proposes ACA Insurance Waiting Period Rule

March 27, 2013 — MACPAC 2013 Report to Congress on Medicaid/CHIP

March 27, 2013 — Recent Reed Smith Analyses of Sunshine Act Rule, ACA Qualified Health Plans, HITECH Final Rule

March 14, 2013 — Reed Smith Alert: ACA Affordable Insurance Exchanges and Qualified Health Plans

March 13, 2013 — HHS Issues Rules to Implement ACA Essential Health Benefit Framework

March 13, 2013 — HHS Issues ACA Benefit, Payment Parameter Rules for 2014

March 13, 2013 — HHS Adopts Final ACA Health Insurance Market Reform Rules

March 13, 2013 — OSHA, IRS, and OPM Release ACA Regulations

March 13, 2013 — HHS Suspends Enrollment in Pre-Existing Condition Insurance Plan (PCIP)

March 12, 2013 — Congressional Hearings

March 5, 2013 — CMS Physician Payment "Sunshine" Final Rule -- Overview and Analysis

February 18, 2013 — CMS, IRS Proposed ACA "Shared Responsibility" Payment/Exemptions Rules

February 18, 2013 — Obama Administration Proposes Revised ACA Contraceptive Coverage Requirements

February 18, 2013 — CMS Moves Forward with ACA Bundled Payments for Care Improvement Initiative

February 1, 2013 — CMS Releases Physician Payments Sunshine Act Final Rule

January 30, 2013 — CMS Proposes Changes to Medicaid Eligibility, Benefits, and Appeals Rules

January 30, 2013 — Senate HELP Committee Hold Hearings on Mental Health, Primary Care

January 29, 2013 — CMS Previews Medicaid Core Set of Health Home Quality Measures

January 29, 2013 — PCORI Seeking Nominations for Advisory Panels

January 14, 2013 — Obama Administration's Regulatory Agenda Points to Busy 2013 for HHS

January 14, 2013 — CMS Announces 90-Day Enforcement Discretion Period for HIPAA Eligibility & Claim Status Operating Rules

January 11, 2013 — Access Board Committee to Meet on ACA Medical Diagnostic Equipment Standards (Jan. 22-23)

January 9, 2013 — IRS Proposes ACA Employer "Shared Responsibility" Requirements for Employee Health Coverage

January 4, 2013 — Fiscal Cliff Deal Includes Medicare Cuts and Other Health Policy Changes

December 20, 2012 — IRS Issues Regulations to Implement ACA Medical Device Tax

December 20, 2012 — IRS Issues Notice on ACA Branded Prescription Drug Fee Parameters for 2013

December 20, 2012 — IRS Regulations Implement Insurer Fee to Fund PCORI Trust Fund

December 18, 2012 — HHS Proposed Rule on ACA Benefit and Payment Parameters for 2014

December 18, 2012 — OPM Proposes Parameters for ACA Multi-State Insurance Exchanges

December 17, 2012 — CMS Seeks Comments on Measures of Patient Experiences with Emergency Department Care