On June 13, 2019, the Trump Administration finalized regulations to expand Health Reimbursement Arrangements (“HRAs”), providing employers with more options for offering health insurance coverage to employees. The final regulations now authorize employers to provide employees with tax-preferred funds to pay for the cost of health insurance coverage purchased in […]
Publications
The Clock Is Ticking: What Employers Should Know to Prepare for EEO-1 Pay Data Submissions
Despite administrative conflicts surrounding the newly revived EEO-1 Component 2 pay data requirements, employers should now begin preparing their compensation data for submission to the Equal Employment Opportunity Commission (“EEOC”). As previously reported here, in April of this year, a federal judge set September 30, 2019 as the deadline for […]
DHHS RFI on Reducing Regulatory Burdens
A new DHHS Request for Information on Reducing Administrative Burden to Put Patients Over Paperwork was published in the Federal Register on June 11, 2019. (84 FR 27070) The comment period is open for 60 days from the publishing date. As described in the notice, “[t]his RFI solicits additional public […]
Update on CMS Co-Location Guidance
CMS released draft guidance regarding requirements under the Conditions of Participation (“COPs”) for hospitals co-located with other hospitals and health care providers. The draft guidance was issued by the Director of the CMS Quality, Safety and Oversight Group on May 3, 2019, and is available here. CMS requested comments regarding […]
Update on CMS Claim Edits for Providers with Multiple Service Locations
CMS has pushed back the full implementation date for claim edits for providers with multiple service locations until October 2019. CMS has piloted claim edits that validate whether the service facility location on the claim form matches exactly the information submitted by the provider on its enrollment forms (CMS-855A) and […]

