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| 02.03.09 | Changes to Part D Reporting Requirements Proposed For Contract Year 2010
American Health Lawyers Association Practice Group Alert
Stephanie B. Vasconcellos
Abstract: The Centers for Medicare & Medicaid Services (CMS) published a Paperwork Reduction Act notice of proposed reporting requirements in 74 Federal Register 3051 to change Medicare Part D reporting starting in contract year 2010. The comment period for the proposed changes ends March 17, 2009. According to a November 24, 2008, letter from CMS to Part D sponsors, CMS intends "to test these proposed reporting requirements with a small number of Part D sponsors prior to CY2010." The letter indicates that CMS will contact selected Part D sponsors to participate in the pilot program. Neal Gerber Eisenberg Health Law Practice Group member Stephanie B. Vasconcellos co-authored an article appearing in the February 3, 2009 American Health Lawyers Association Practice Group Alert that was distributed to the Association's Medicare Part D Task Force Members.
Click here to view the full article (subscription required)
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| 01.30.09 | Should Dating Co-Workers Sign a "Love Contract"?
Costco Connection
David B. Ritter
Abstract: With statistics showing that nearly 40 percent of workers have dated a co-worker, it’s naive to think that office romances can be stopped; even if a company were to implement a no-dating policy, it is nearly impossible to manage or enforce such a policy. A “love contract” may just be the best tool around to manage such situations. Neal Gerber Eisenberg partner and Labor & Employment Practice Group chair David B. Ritter is a contributing author of an article that appears in the February 2009 edition of Costco Connection.Click here to view the full article. |
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| 01.30.09 | Protecting Against Gun Violence in Workplace
Chicago Daily Law Bulletin
David B. Ritter, Sonya Rosenberg
Abstract: Despite the struggling economy, stores around the country are reporting an interesting phenomenon: gun sales are going up. Whatever the cause, growing gun sales have employers worried. And understandably so. Recent developments raise serious questions about the safety of the workplace and an employer's continued ability to protect its workplace from the dire consequences of gun violence. Neal Gerber Eisenberg partner and Labor & Employment Practice Group chair David B. Ritter and Labor & Employment Practice Group member Sonya Rosenberg co-authored an article that appears in the January 30, 2009 issue of Chicago Daily Law Bulletin.Click here to view the full article (subscription required). |
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| 01.28.09 | CMS Requires Medicare Part D Cost Transparency, Expands Beneficiary Protections and Tightens SNP Rules
Stephanie B. Vasconcellos
Abstract: The Centers for Medicare and Medicaid Services (CMS) amended, on January 12, 2009 in 74 Federal Register 1493, the Medicare Advantage (MA) and Medicare Prescription Drug (Part D) Rules to require cost transparency in the Part D prescription drug prices reported to CMS, to expand beneficiary protections, and to tighten the rules applicable to MA special needs plans (SNPs). CMS issued an additional amendment to the Part D Rule on January 16, 2009 in 74 Federal Register 2881 to reflect changes in Part D formulary requirements made by the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA).On January 20, 2009, the Obama Administration White House Chief of Staff issued a directive to the heads of all executive departments and agencies to, inter alia, “[c]onsider extending for 60 days the effective date of regulations that have been published in the Federal Register but not yet taken effect.” See 74 Fed. Reg. 4435 (Jan. 26, 2009). The Part D Rule amendment published January 16 is not impacted by the directive because this amendment took effect immediately upon its publication in the Federal Register. The MA and the Part D Rule amendments published January 12 may be impacted. Consequently, if and when those amendments become effective and their compliance dates must be met is uncertain. As a result, the effective and compliance dates for those amendments set out within this Alert may change. |
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| 01.28.09 | Medicare Retiree Drug Subsidy Plans May be Excepted from “Pass-Through” Part D Drug Price Reporting
Abstract: Since the inception of the Medicare prescription drug (Part D) program in 2006, both sponsors of Part D prescription drug plans (Part D plan sponsors) and employers sponsoring retiree prescription drug plans eligible for federal subsidy payments (RDS-plan employers) have been permitted to report to the Centers for Medicare and Medicaid Services (CMS) either the “lock-in” price they pay to their pharmacy benefit managers (PBMs) for dispensed Part D drugs or the “pass-through” price that their PBMs pay to pharmacies for dispensed Part D drugs. |
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