If you read only last Thursday’s headlines, you probably concluded that the Administration had decided not to enforce the ACA’s 2014 health care coverage mandates until after the 2016 Presidential election.  If you clicked the hyperlinks and read the actual CMS notices, you got a headache, as did your humble correspondent.  As a supplement to

We leave to the media what it does well for you – recent reportage of ACA-induced policy cancellations and premium increases, for example.  This blog examines ACA-related risks and opportunities that our employer, insurer and provider clients have not yet identified or understood adequately.  Here’s a problem that is just coming into focus.

Since late

In recent weeks, media have been abuzz with stories about families whose existing individual health insurance policies are being cancelled because they do not comply with the ACA.  Just moments ago, President Obama announced that health insurance companies, under certain circumstances, will be allowed to renew these plans for one more year.

While the President

Effective for plan years beginning after December 31, 2013, the ACA requires issuers of non-grandfathered group health coverages to renew those coverages at the option of the plan sponsors.  An issuer may refuse to renew a policy that is being withdrawn from the market, as long as ACA-compliant substitutes are offered.  If so, the issuer

Periodically, federal government agencies must disclose the status of all major rulemaking projects, forecasting the dates of expected rule publications.  The Spring 2013 version of this “Semi-annual Regulatory Agenda” was released July 23, 2013.   Here is the reported status of eleven major ACA rulemaking projects.

The individual mandate final rule is expected to be published

The Affordable Care Act’s impact on hospital mergers and acquisitions has been duly noted and seriously considered by corporate and bond counsel.  But the ACA’s application to similar transactions not involving health care providers should be getting the attention that it deserves, too.  Of particular concern are anti-abuse rules designed to stop employers from shifting