27 January 2016

CMS Releases Revised Guidelines on the Two-Midnight Rule

The Centers for Medicare and Medicaid Services (“CMS”), through the Medicare Learning Network, recently released revised guidelines on the Two-Midnight Rule. The Two-Midnight Rule has long been a thorn in the side of many health care providers and has been the subject of countless Medicare Administrative Contractor (“MAC”) and Recovery Audit Contractor (“RAC”) appeals. The […]


27 January 2016

HIPAA and Individuals’ Right to Access their Health Information

The Department of Health and Human Services rang in the New Year by releasing updated guidance on patients’ right to access their health information. The updated guidance is a good opportunity for health care providers to revisit their practices, policies and procedures and make any necessary changes. The guidance reminds covered entities that individuals have […]


19 January 2016

IRS Clarifies a Number of Health Care Reform Compliance Issues

“It’s as clear as mud.” That is the frustrating answer to many employer questions related to Health Care Reform. But, with a law the size of the Affordable Care Act (ACA), there are always a number of “holes” that need to be filled with regulatory guidance. But regulatory guidance is a slow process, so it […]


19 January 2016

Priority Alert – Health Care Reform, January 19, 2016

The IRS recently released IRS Notice 2015-87, which—in 31 pages—provides additional guidance related to the ACA and other, more general, health and welfare plan compliance issues. “IRS Clarifies a Number of Health Care Reform Compliance Issues” provides a brief summary and covers affordability, adjustments for inflation, HRAs, hours of service, medical FSA carryovers and more. Also, did you catch these related Client Alerts we sent in December?


11 January 2016

New Real Property Tax Legislation Fixes Hole in Uncapping Exemption

Much awaited legislation was passed before year-end addressing what real estate and estate planning practitioners believed was a “hole” in Michigan’s uncapping exemption: those transfers subject to a life estate or enhanced life estate (aka ladybird transfers). On December 22, 2015, Governor Snyder signed into law PA 243, which amends MCL 211.27a to include transfers […]