House plans five-hour debate on healthcare repeal, WH warns veto
By Pete Kasperowicz
Source: thehill.com/blogs
The House will hold five hours of debate today and Wednesday on legislation that would completely repeal the 2010 healthcare law, which is being called up by Republicans in light of the Supreme Court's decision that the individual health insurance mandate is constitutional.
The House Rules Committee approved a rule late Monday setting out the lengthy debate on a bill that is expected to pass with Republican support, but very little if any Democratic support. The Repeal of Obamacare Act, H.R. 6079, was formally introduced by House Majority Leader Eric Cantor (R-Va.) on Monday.
Later Monday evening, the White House put out a statement saying President Obama would veto the bill if it were presented for his signature, something that won't happen given Senate opposition.
"The Administration strongly opposes House passage of H.R. 6079 because it would cost millions of hard-working middle class families the security of affordable health coverage and care they deserve," the statement said. "It would increase the deficit and detract from the work the Congress needs to do to focus on the economy and create jobs.
"The last thing the Congress should do is refight old political battles and take a massive step backward by repealing basic protections that provide security for the middle class, it added. "Right now, the Congress needs to work together to focus on the economy and creating jobs. Congress should act on the President's concrete plans to create an economy built to last by reducing the deficit in a balanced way and investing in education, clean energy, innovation, and infrastructure.
"If the President were presented with H.R. 6079, he would veto it."
Under the rule for the House bill, the House Committees on Education and the Workforce, Energy and Commerce, and Ways and Means will each control one hour of debate. House Committees on Budget, Judiciary and Small Business will each control 30 minutes.
Finally, Majority Leader Cantor and House Minority Leader Nancy Pelosi (D-Calif.) and/or their designees will split the last 30 minutes of debate time.
The House is expected to start work on the bill by debating and approving the rule, which will take an hour early this afternoon. A final vote on passage on the bill itself is expected Wednesday.
IFEBP survey: More than 75% of sectors will provide health coverage in 2014
By Marli D. Riggs
July 2, 2012
Source: https://eba.benefitnews.com
Despite the differing reactions among U.S. business sectors to last week’s Patient Protection and Affordable Care Act Supreme Court ruling, 77% of surveyed organizations are very likely to provide health coverage in 2014, according to a recent survey by the International Foundation of Employee Benefits Plans.Following the Supreme Court’s decision, almost half (49%) of the organizations are shifting their attention to wellness, while 32% are focusing on consumer-driven health plans, 27% will shift costs to employees and 26% will focus on value-based health care, according to The Supreme Court ACA Decision Reaction Survey.
“We’re not surprised by these findings since our recent wellness survey told us that seven in 10 U.S. employers offer wellness programs,” says Paul Hackleman, IFEBP’s health care and public employer analyst.
Overall, the results were split when respondents identified which Supreme Court decision would have been most beneficial to their organization. The data showed that 46% felt the best possible decision for their organization would have been PPACA being thrown out, while 41% said the best decision was the law being upheld. Another 12% of organizations would have liked the individual mandate overturned, but the remainder of the health care law to stay intact.
Most organizations have been keeping current with the legislative aspects of PPACA and some are already prepared for provisions in the future. Of the respondents 78% are extremely or very far along in terms of complying with current PPACA provisions, while 60% are extremely or very far along with preparing for future provisions.
Further, organizations in states that have already implemented health care exchanges are generally more satisfied with the Court’s decision (47% to 35% of respondents in states that haven’t implemented), and are more prepared with current provisions (47% to 36%) and more likely to continue coverage in 2014 (56% to 42%).
The survey was administered on June 28 to measure organizations’ reactions to the landmark decision. Responses were received from 1,122 plan administrators, trustees and organizational representatives.
Businesses won't wait for elections before implementing health law
By Sam Baker
July 9, 2012
Source: thehilll.com/blogs/healthwatch
Most businesses waited for the Supreme Court before making plans to comply with President Obama’s healthcare law — but most aren’t waiting for November to see whether the law might be repealed.
A new survey from the consulting firm Mercer found that most businesses have not begun planning for requirements that will take effect in 2014, including the mandate requiring employers to provide health benefits to most workers.
Businesses said they were holding off on implementation until they knew whether the Supreme Court would strike down the healthcare law — the same approach many Republican governors have taken. But now that the court has upheld the law, only 16 percent of the employers in Mercer’s survey said they plan to wait for November and the prospect of legislative repeal.
Mercer surveyed 4,000 businesses immediately following the high court’s decision.
The National Federation of Independent Business (NFIB), the country’s largest small-business organization, joined 26 state attorneys general in filing the legal challenge to the Affordable Care Act. Republicans consistently argue that the law will burden small employers and stifle new hiring.
But only 28 percent of the employers in Mercer’s survey said the new employer mandate will pose a “significant challenge.” The law requires many businesses to offer healthcare coverage or pay a penalty for all workers who buy coverage on their own, with help from the federal government.
“Employers with large part-time populations, such as retailers and healthcare organizations, are faced with the difficult choice of either increasing the number of employees eligible for coverage or changing their workforce strategy so that employees work fewer hours,” said David Rahill, president of Mercer’s Health and Benefits business.
How can company policies prevent injury?
Source: https://www.riskandinsurance.com
Implementing, enforcing policies can improve bottom line, study suggests
Prescription drug abuse, texting, and falls by older adults are among the emerging injury threats cited in a new study. It suggests policymakers and others implement and enforce policies to reduce preventable injuries.
More than $400 billion is spent annually in lifetime costs for medical care and lost productivity resulting from injuries. While the report focuses on steps states can take to prevent injuries, the recommendations are also appropriate for employers trying to reduce workers' comp costs and improve their bottom lines.
Injuries are the third-leading cause of deaths nationally, according to the researchers. Among the most common types are:
- Falls. "More than eight million Americans suffer falls that require medical attention each year," it says. One in three people age 65 and older experiences a fall annually, and falls are the leading cause of injury deaths in adults over 65 years of age. Falls can be reduced "by as much as half" among participants involved in exercise programs.
- Violence. Injuries caused by intimate partners alone cause more than 2,000 deaths a year. Nearly three in 10 women and one in 10 men have experienced physical violence, rape, or stalking by a partner.
- Misuse and abuse of prescription drugs. The report notes the dramatic increase in the past decade, saying prescription painkillers are responsible for approximately 15,000 deaths and 475,000 emergency room visits a year.
For employers, injuries mean lost productivity as well as increased workers' comp and health care costs. Adults between the ages of 25 and 44 comprise 30 percent of the U.S. population but account for 44 percent of injury-related productivity losses.
Overall, businesses lose $326 billion in productivity annually due to injuries. Motor vehicle and other road-related accidents are responsible for $75 billion of the total while falls account for $54 billion, and struck by or against costs $37 billion.
"Many injuries are predictable, preventable and controllable," according to the study. "For instance, researchers found that seat belts can greatly reduce the harm caused to individuals in motor vehicle crashes."
The study, The Facts Hurt: A State-by-State Injury Prevention Policy Report, cites research showing seat belts saved an estimated 69,000 lives between 2006 and 2010. However, 18 states do not have primary seat belt laws.
Thirty-one states do not require helmets for all motorcycle riders, although research says they saved an estimated 8,000 lives from 2005 to 2009.
The researchers ranked the states in terms of their injury prevention efforts based on 10 key indicators. They included whether the state has enacted a prescription drug monitoring program, whether it has a primary seat belt law, and whether it requires a helmet for all motorcycle riders.
California and New York received the highest score while Montana and Ohio netted the lowest.
"Millions of injuries could be prevented each year if more states adopted additional research-based prevention policies and if programs were fully implemented and enforced," the report says.
"We could dramatically bring down rates of injuries from motor vehicles, assaults, falls, fires and a range of other risks even more if more states adopted, enforced and implemented proven policies," said Amber Williams, executive director of the Safe States Alliance. Hers was one of several groups that teamed up with the Trust for America's Health and the Robert Wood Johnson Foundation for the study.
The Long Arm Of The U.S. Healthcare Ruling
Source: https://www.insurancebroadcasting.com
The Supreme Court ruling to uphold the core of President Barack Obama's 2010 healthcare law has wide-ranging political and economic implications.
Here is a snap analysis of what it means for Americans, healthcare providers, insurers, the law and the presidential campaign.
How does the ruling affect the average American?
* Working families with annual household incomes up to nearly $90,000 will be able to purchase private insurance through new state insurance markets at prices subsidized according to income level, beginning in 2014. But people with household incomes of around $29,000, who qualify for coverage under the Medicaid government health insurance program for the poor, may have to wait for their respective state governments to decide whether they will join the program's huge expansion. Preventive healthcare measures including mammograms and other cancer screenings will be available without deductibles or co-pays. Adult children up to age 26 can remain on their parents' health insurance plans. Senior citizens can expect to continue receiving discounts on prescription drugs aimed at closing the Medicare coverage gap known as the "doughnut hole." Health insurers will continue to pay rebates on premiums not sufficiently targeted at healthcare services. Beginning in 2014, insurers will no longer be able to deny coverage to adults with pre-existing medical conditions and would be required to stop or curb discriminatory pricing based on gender, age and health status.
What about healthcare providers?
* The ruling removes one cloud of uncertainty over the future of healthcare reform and would help the administration's efforts to implement it fully by January 1, 2014, when the law is scheduled to go into effect. Under the decision, physicians and hospitals continue to move away from the traditional fee-for-service healthcare business model and toward more efficient systems that coordinate care. For healthcare providers, the affirmation represents millions of potential new patients, either through private plans or the government's Medicaid program for the poor. Some, however, would be under added pressure to enact more savings, which could cut into revenues. The administration still faces some fairly tall hurdles, such as establishing regulated health insurance markets in all 50 states so consumers can purchase subsidized coverage. Up until now, over a dozen states have done little or nothing to create such exchanges, partly because of the uncertainty over the fate of the law. Down the road, if Republicans succeed in taking control of the White House and the Senate in November (they already control the House of Representatives), they would likely try to repeal the law in 2013.
Where does the ruling leave health insurers?
* The health insurance industry can expect premium revenue from millions of new, healthy customers through state exchanges. But the industry will also have to operate with new consumer protections that require coverage access for people with pre-existing medical conditions and other health status issues, and mandate preventive care without customary charges.
How might the ruling influence the presidential campaign?
* This is a big victory for Obama, who has weathered years of criticism from conservatives about his reforms. The decision could energize the president and his supporters, while undercutting presumptive Republican presidential nominee Mitt Romney, who introduced similar reforms as Massachusetts governor but opposes their use as national policy. But there could be a silver lining for Republicans: the opinion could light a fire under party candidates and constituents who want a president who would repeal the law in 2013.
(Reporting by David Morgan and Lewis Krauskopf; Editing by Michele Gershberg and Will Dunham)
OVERVIEW OF MEDICAL LOSS RATIO REBATES
The Affordable Care Act requires health insurers to spend a minimum percentage of their premium dollars on medical claims and quality improvement. Insurers in the large group market must achieve a medical loss ratio (MLR) of 85%, while insurers in the individual and small group markets must achieve an MLR of 80%. Insurers that fail to achieve these percentages must issue rebates to their policyholders. The first of these MLR rebates are due in August of 2012, so plan sponsors should begin planning how to handle any rebates they might receive.
Which Plans Are Covered?
The MLR rules apply to all fully insured health plans (even grandfathered plans). Self-funded plans are exempt. Certain types of insured coverage, such as fixed indemnity, stand-alone dental and vision, and long-term disability, are also exempt.
If a rebate is payable to a group policyholder, the insurer must issue a single rebate check to the plan. The plan sponsor must then decide whether and how to pass the rebate on to the plan's participants.
Calculating a Medical Loss Ratio
The calculation of an MLR is not specific to each policyholder, but is a state-by-state aggregate of the insurer's overall MLR within a particular market segment (e.g., individual, small group, or large group). Thus, even if a specific employer plan has a low MLR (i.e., favorable claims experience), the employer may not necessarily receive a rebate.
States are permitted to set higher MLR targets. In those states, insurers must comply with the more stringent state requirements.
Notices to Subscribers
Insurers must send written notices to their subscribers, informing them that a rebate will be issued. Plan sponsors should be prepared to respond to questions from participants who receive these notices, particularly if the sponsor does not intend to share any of the rebate with those participants.
Likewise, even if an insurer meets the MLR requirements, it must notify subscribers that no rebate will be issued. This notice must be included with the first plan document provided to enrollees on or after July 1, 2012. Model notices<https://cciio.cms.gov/programs/marketreforms/mlr/index.html> are available on the Centers for Medicare & Medicaid Services website.
How to Allocate MLR Rebates
The Department of Labor (DOL) issued Technical Release 2011-04<https://www.dol.gov/ebsa/newsroom/tr11-04.html>, summarizing how ERISA plan sponsors should handle MLR rebates. To the extent that all or a portion of the rebate constitutes a "plan asset," the sponsor may have a fiduciary duty to share the rebate with plan participants.
In the absence of specific plan or policy language, the determination of whether an MLR rebate is considered to be a plan asset will depend, in part, on the identity of the group policyholder. If the plan or trust is the policyholder, the MLR rebate will likely be considered a plan asset under ordinary notions of property rights.
However, if the employer is the policyholder, the determination will hinge on the source of the premium payments and the percentage of premiums paid by the employer, as opposed to plan participants. If the premiums were paid entirely out of plan assets, the DOL's view is that the entire amount of the rebate would be considered a plan asset. In other circumstances, only the portion of the rebate that is attributable to participant contributions will be considered a plan asset.
If all or a portion of a rebate does constitute a plan asset, then the plan sponsor will have to determine how and to whom to allocate the rebate. For example, must a portion of the rebate be allocated to former plan participants? The selection of an allocation method must be reasonable and it must be made solely in the interest of plan participants and beneficiaries.
However, a plan fiduciary may weigh the costs to the plan - and the ultimate plan benefit - when deciding on an allocation method. Thus, for example, if the cost of calculating and distributing shares of a rebate to former participants approximates (or exceeds) the amount of the proceeds, a fiduciary is permitted to limit the allocation to current plan participants.
Similarly, if it is not cost-effective to distribute cash payments to plan participants (because the amounts are de minimis, or they would produce negative tax consequences for the participants), a fiduciary may use the rebate for other permissible plan purposes. These might include a credit against future participant premium payments or benefit enhancements.
Tax Consequences
Before deciding to pass an MLR rebate on to participants, a plan sponsor will want to understand the tax implications of doing so. The IRS has issued a set of questions and answers<https://www.irs.gov/newsroom/article/0,,id=256167,00.html> on this topic. Because this guidance is entirely in the form of examples, with few general principles provided, the tax treatment may not always be clear. What is clear is that a number of factors will affect the taxability of an MLR rebate.
For individual policyholders receiving an MLR rebate, the IRS treats the rebate as a return of premiums (i.e., a purchase price adjustment). As long as the premium payments were not deducted on the individual's federal tax return, the MLR rebate should not be taxable. However, if an individual did deduct the premium payments, the MLR rebate will be taxable to the extent the individual received a tax benefit from that deduction.
For participants in a group plan, the tax consequences will depend on factors such as the source of the premium payments (employer versus participant), whether participant premiums were paid on an after-tax or pre-tax basis, and whether a participant who paid premiums on an after-tax basis later deducted those premiums on his or her federal income tax return.
Another key factor is whether the rebates are passed through only to participants who participated in the plan during both the year to which the rebate relates and the year it is received, or to all participants who participate during the year the rebate is received (i.e., without regard to whether they also participated during the year to which the rebate relates).
For instance, if a participant paid premiums on an after-tax basis and the MLR rebate is specifically conditioned on the participant having participated in the plan during both the year to which the rebate relates and the year it is received, any rebate allocated to that participant will generally not be taxable - regardless of whether the rebate takes the form of a cash payment or a reduction in future premium payments. However, if the participant claimed a tax deduction for the premium payments (as might be the case for a self-employed individual), the rebate will be taxable to that participant.
On the other hand, if an MLR rebate is passed through to all current plan participants (regardless of whether they participated in the plan during the year to which the rebate relates), the rebate should not be taxable even if a participant took a tax deduction for premiums paid during that year.
Finally, if a participant paid premiums on a pre-tax basis (i.e., through a cafeteria plan), the return of those premiums - whether received in cash or as a credit against future premiums - will be subject to both income and employment taxes.
SUPREME COURT LARGELY UPHOLDS PPACA
The U.S. Supreme Court upheld the individual mandate and most of the Patient Protection and Affordable Care Act (PPACA). As expected, it was a close decision -- 5-4 -- with Chief Justice Roberts and Justices Breyer, Ginsburg, Kagan and Sotomayor agreeing that the individual mandate is a permissible tax. Because the individual mandate was found to be acceptable, most of the rest of the law (including the exchanges and the requirement that larger employers provide minimum coverage or pay penalties of their own) automatically stands.
Because PPACA has been upheld, employers need to move forward with implementing the changes required by the law. The most immediate requirements are:
- All group health plans, regardless of size, must provide "summaries of benefits coverage" (SBC) with the first open enrollment beginning on or after Sept. 23, 2012. The content and format of these SBCs must meet strict guidelines, and the penalties for not providing them are high (up to $1,000 per failure). Insurers will be expected to provide the SBCs for fully insured plans, while self-funded plans will be responsible for preparing their own.
--- - Employers that issued 250 or more W-2s in 2011 must report the total value of each employee's medical coverage on their 2012 W-2 (which is to be issued in January 2013).
--- - High income taxpayers (those with more than $250,000 in wages if married and filing jointly, or more than $200,00 if single) must pay additional Medicare tax, and employers will be responsible for deducting a part of the tax (an additional 0.9 percent on the employee's wages in excess of $200,000) from the employee's pay beginning in 2013.
--- - The maximum employee contribution to a health flexible spending account (FSA) will be $2,500 beginning with the 2013 plan year.
--- - The Patient Centered Outcomes fee (also called the comparative effectiveness fee) is due July 31, 2013. The fee is $1 per covered life for the 2012 year. Insurers will remit the fee on behalf of the plans they cover, while self-funded plans will pay the fee directly.
Politically, while House Republicans have pledged to repeal PPACA, it is unlikely a repeal bill would pass the Senate, and it would be vetoed in any event by President Barack Obama. The fall elections, of course, could result in a change in control of Congress and/or the White House, and Republican victories would likely re-energize efforts to repeal PPACA or to discontinue funding needed to implement various parts of the law.
The opinion is long (193 pages) and complex, and we will provide additional details -- through both written alerts and a webinar -- once there has been more time to study the opinion.
Mixed Small Business Reaction to Health Ruling
By Emily Maltby and Sarah E. Needleman
Source: wsj.com
If there’s one thing many small-business owners can take away from the Supreme Court’s decision to uphold the Affordable Care Act, it’s a little more certainty.
Consider Richard Balka, owner of The Home Rubber Company L.P. in Trenton, N.J., which offers health insurance to its 37 employees. He said Thursday that he was pleased that the Supreme Court upheld the provision that ensures people can get coverage despite having a pre-existing health condition.
“That freed my conscience in the event I have to stop offering health care to my employees,” he said. “If I had dropped it, anyone who either had a pre-existing condition or family member with a pre-existing condition would be in a horrible position.”
The Supreme Court voted 5-4 to uphold a provision requiring taxpayers to carry health insurance or pay a penalty. The majority opinion, by Chief Justice John Roberts, found that the penalty effectively functioned as a tax, by increasing the income taxes of those without qualifying insurance, and was therefore justified under Congress’ constitutional power to levy taxes and provide for the general welfare.
Of course, the decision still leaves small-business owners wondering how the law will impact the cost of health care.
Some expect the law to lead to lower health-care premiums, with the cost of health care spread among a larger pool of insured Americans. Others, though, predict that premiums will rise and worry that they’ll be forced to provide coverage that they can’t afford, starting in 2014, when many of the law’s key provisions take effect.
Even Mr. Balka said he is still concerned that health exchanges, expected to roll out at the state level come 2014, “may not go far enough” to curb the cost of providing insurance to employees.
Premiums at the rubber-manufacturing facility have increased between 8% and 20% each year in the last 15 years.
Makini Howell, owner of Plum Bistro, a group of four vegan restaurants in Seattle, had no reservations about Thursday’s ruling. “It’s a good thing it wasn’t shot down because we wouldn’t be able to offer coverage,” she said.
Plum Bistro began offering insurance to its eight full-time employees about three months ago. Ms. Howell credits a small-business tax break that rolled out as part of the law as one reason for her ability to offer insurance. She is also looking forward to the health exchanges, which, she believes, could “level the playing field for us.”
Some small-business owners say the law doesn’t affect them now, but voiced concern about how provisions of the law might impact their plans to add to their payroll as they grow.
Elie D. Ashery, president of Gold Lasso Inc., a 10-year-old Gaithersburg, Md., marketing firm, currently has 25 employees and is growing fast, he said. He thinks the law will only push premiums higher.
Though the firm offers health insurance, its premiums have been rising by 26% on average annually over the past four years, he added.
If the firm’s headcount rises above 50, then it might turn out to be less costly to pay a penalty than continue to provide health insurance. “It’s an option I’d have to consider,” he said.
Ruling Lifts Cloud of Uncertainty Over Health Industry
By Ron Winslow
Source: blogs.wsj.com
The Supreme Court’s decision largely upholding the Accountable Care Act lifts a huge cloud of uncertainty over the health-care industry and sets companies and hospitals back on a course to prepare for the bulk of the law’s implementation over the next two years.
As WSJ’s Anna Mathews reports: One-sixth of the U.S. economy just started breathing again.
Health insurers and hospitals were already embarked on a host of strategic changes to prepare for the law as well to respond to as growing pressure in the marketplace to contain costs and improve quality of care.
The decision affirms hospital initiatives that were launched even before the law was passed in 2010 to consolidate and make strategic investments in outpatient clinics and information technology, as WSJ’s Chris Weaver reports.
“We’ll have 32 million potential customers who will come in, get treatment and pay,” saysAlan Miller, the chief executive of Universal Health Services, a hospital operator. “Previously, they got good treatment, and said, ‘we can’t pay.’”
Meantime, the pharmaceutical industry is generally pleased with the decision as it supported the law and also stands to gain from tens of millions of new insured. But that will be offset by billions in fees and other concessions.
Investors reacted to the decision by bidding up hospital stocks while punishing health insurers’ shares in a broadly down market. Pharmaceutical, biotech and medical device stocks also generally fell.
To be sure, while the law’s constitutionality was upheld in today’s decision, the political debate is further inflamed ahead of the November election, which means additional uncertainty lies ahead.
Employer Penalties Under Healthcare Reform
By Joe Giangola
One of the most misunderstood areas of Healthcare Reform has been the mandating of coverage and the associated penalties for employers. There is a lot of confusion as to who the mandates will apply to, when they will begin and who must be covered. Fortunately the mandates do not begin until 2014, which should give employers ample time to prepare.
Company Size and Who is Affected?
Let's take a look at who will be affected by the law. The PPACA (Patient Protection & Affordable Care Act) mandates will apply to companies with 50 or more full time employees.
How exactly is the company size determined? The employer must employ 50 or more full time employees for 120 or more days in the preceding calendar year. So your number of employees in 2013 will determine whether the law applies in 2014.
An employee is considered full time if they work an average of 30 or more hours per week. The law also takes into account part time employees as they are counted as full time equivalents. Part time employees are used to help determine who must comply with the law but are not used in the calculation of the penalties.
Who and what must be covered?
In 2014 an employer must offer minimum essential coverage to all of it's full time employees and their dependents. Failure to comply will subject the employer to a $2,000 per year penalty per employee over 30 employees. This can also result if any full time employee receives subsidized coverage through an Exchange.
What will be considered minimum essential coverage?
The Federal Government's office website, healthcare.gov , defines Minimum Essential Coverage as follows:
"The type of coverage an individual needs to have to meet the individual responsibility requirement under the Affordable Care Act. This includes individual market policies, job-based coverage, Medicare, Medicaid, CHIP, TRICARE and certain other coverage."
As you can see the law is not clear as to the level of coverage required, your current plan may exceed or fall short of the law's required level of benefits.
Will offering a plan make my company compliant with the PPACA?
First, your plan must meet the, to be determined, essential level of coverage. Second, your plan must be considered "affordable" and offer "minimum value".
Employees who are eligible for coverage through work are able to receive subsidized coverage through the Exchanges created by the PPACA. An employee may qualify for a subsidy if their income falls below 400% of the Federal Poverty Level, $88,200 per year for a family of four or $43,320 per year for an individual. The employer must pay 60% of the allowed costs of the coverage and the employees contribution may not exceed 9.5% of their household income. This number will be virtually impossible for employers to determine since spouses income will be unknown.
The penalty for non-compliance is $3,000 per employee over the first 30. The penalty cannot be greater than $2,000 per employee for failure to provide coverage. After 2014 the penalty can be indexed.
Many questions remain unanswered at this time leaving business owners helpless to prepare for the upcoming changes. Be sure to check back often as I will be keeping a close eye on the developing regulations from the Department of Health and Human Services and will help explain the pending clarifications as they are released.