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§4980H Affordability – Opt-Out Guidance

The Internal Revenue Service (IRS) has released proposed rules addressing the relationship between opt-out arrangements and affordability for purposes of subsidy eligibility through a public Exchange and potential §4980H(b) penalties. First addressed in Notice 2015-87 last December, the proposed rules confirm and further clarify that unconditional opt-out payments need to be added to the employee contribution for purposes of determining affordability, while conditional opt-outs generally do not.

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HHS Releases Discrimination Rule Affecting Transgender Benefits

The Department of Health and Human Services (HHS) recently released the Final Rule implementing Section 1557 of the Affordable Care Act (ACA), which prohibits certain types of entities from discriminating in health programs on the basis of race, color, national origin, age, disability or sex (including gender identity-based discrimination). Most affected entities are not likely to have discrimination issues related to most of these categories; however, the new rules include significant requirements related to health coverage for transgender individuals that may force changes to current benefits.

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Providence-Swedish Health & Services May Be Leaving Premera Blue Cross

We received notice late Wednesday that Providence-Swedish Health & Services has decided to terminate their contract with Premera Blue Cross, effective January 1, 2017.
At this time we do not know if this decision to terminate is a final position on the part of Providence or part of their negotiations with Premera.

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Minimizing Healthcare Regulatory Risk

Regardless of your role within the healthcare space, everyone can have an impact on how an organization minimizes regulatory risks. Healthcare executives need to understand the trending regulatory claims, the best way to partner with insurance associates, and how varying policies interface with the associated liabilities.

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