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What television show influenced Chad Jarboe's decision to pursue a career in the legal field? Find out more>

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Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Thought Leadership

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Thought Leadership Spotlight

Healthcare Transactions: Year in Review 2018Last year, CVS Health Corp. (NYSE: CVS) announced it would purchase health insurer Aetna Inc. (NYSE: AET) for $67.5 billion, a transaction that would be one of the biggest healthcare mergers in the past decade. The transaction raises an intriguing question: is this the beginning of a transformational shift in healthcare?

Recently, members of our healthcare group authored the Healthcare Transactions: Year in Review outlining 2017 M&A activity and drivers in the following hot healthcare sectors:

• Managed Care
• Hospitals
• Post-Acute Care—Home Health & Hospice
• Ambulatory Surgery Centers (ASCs)
• Healthcare Information Technology (HIT)
• Behavioral Health
• Physician Practice Management

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DOL Suspends March 23, 2012 Due Date for Distribution of Summary of Benefits and Coverage

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November 18, 2011

On November 17, the Department of Labor ("DOL"), with the assistance of the Departments of Treasury and Health and Human Services, provided welcomed (albeit ambiguous) relief regarding the new Summary of Benefits and Coverage ("SBC") required to be distributed by group health plans and health insurance issuers ("insurers") subject to the requirements of the Affordable Care Act. (We described the availability of the proposed SBC template on page two of our Health Reform Impact alert issued on October 5, available here.)

Until this DOL announcement, the deadline for initially distributing the SBC was to be March 23, 2012. However, the DOL's newest set (Part VII) of Frequently Asked Questions About Affordable Care Act Implementation (available here), describes that compliance with the SBC requirements will be not be required until an applicability date to be announced in forthcoming final regulations on the subject. Although the DOL did not provide—or even hint at—a particular date, the DOL anticipates that this applicability date (i.e., including the initial SBC distribution deadline) will give plans and insurers "sufficient time to comply" with the SBC requirements.

This DOL announcement similarly suspends the requirement that group health plans and insurers provide 60 days' prior notice of any "material modifications" in the terms of the plan or coverage described in the most recently issued SBC.

We await further guidance from the DOL on the SBC applicability date, and will keep you informed of any developments.

If you have any questions about this issue of Health Reform IMPACT, please contact any of the attorneys in our Employee Benefits Practice Group.


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