Helaine I. Fingold, Senior Counsel in the Health Care and Life Sciences practice, in the firm’s Baltimore office, and M. Brian Hall, IV, an Associate in the Health Care and Life Sciences practice, in the firm’s Washington, DC, office, were quoted in Employee Benefits News, in “CMS Audits of Qualified Health Plans to Focus on Broker Standards,” by Melissa A. Winn.

Following is an excerpt:

“Issuers should not expect this policy to continue indefinitely and should be prepared for a CMS QHP compliance review,” say legal experts Helaine Fingold and Brian Hall of Epstein Becker Green.

In 2014 audits, the agency found a lack of familiarity with QHP requirements, they say in a client alert, adding that “many of the examined policies and procedures were non-existent, had been recently created prior to the audit date, or did not address QHP-specific requirements.”

If a QHP issuer “fails to implement policies and procedures that reflect FFM requirements, then it will be difficult for the issuer to demonstrate that it has acted in good faith,” they caution.

This article quotes “CMS Announces Key 2015 Compliance Priorities for Federally Facilitated Exchange Plans,” a Health Care and Life Sciences Client Alert authored by Ms. Fingold and Mr. Hall. 

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