Publications

In a May 1, 2019, Revenue Procedure, the IRS expanded the determination letter program to reach statutory hybrid plans and plan mergers. As background, in 2017, the IRS significantly narrowed the application of its determination letter program for individually designed qualified plans. Prior to 2017, individually designed retirement plans were […]

In a whirlwind few weeks, the fate of the EEO-1 Pay Data requirement (referred to as “Component 2”) was finally decided…or was it? As a quick refresher, the EEO-1 survey must be filed annually by private employers with 100 or more employees, and by federal contractors with 50 or more […]

In late March, South Dakota Republican Senator John Thune introduced S. 895 that would permanently extend the Centers for Medicare & Medicaid Services’ enforcement instruction to its contractors that Critical Access Hospitals do not need to provide direct supervision for outpatient therapeutic services furnished in its facilities. In general, CMS […]

HHS again makes HIPAA enforcement-related headlines, but not for the same reason it had in the recent past. At the end of April, HHS issued a “Notification of Enforcement Discretion Regarding HIPAA Civil Monetary Penalties” (the “Enforcement Discretion Notice”) in which it announces reduced annual limits for HIPAA violations based […]

Beginning on April 1, 2019, CMS started using a Preclusion List as a basis for denying claims for Medicare Advantage, Part D and PACE claims. The concept of the Preclusion List was finalized a year earlier in CMS-4182-F, Contract Year 2019 Policy and Technical Changes to the Medicare Advantage Cost […]