In May, the Federal Trade Commission (“FTC”) proposed changes (the “Proposed Rule”) to the Health Breach Notification Rule (the “Rule”),[1] which, among other items, emphasize that the Rule applies to mobile health applications and related technologies that use or otherwise compile consumers’ health information.[2] While the FTC’s position on this point is not entirely new,[3] industry interpretations of the Rule have been inconsistent.Continue Reading FTC Proposes Changes to Health Breach Notification Rule Clarifying Application to Health and Wellness Apps
Jason Levy
Jason Levy is an associate in the Corporate Practice Group in the firm's Century City office and is a member of the firm’s Healthcare team.
CMS Releases Notice of Benefit and Payment Parameters for 2024 Final Rule
On April 17, 2023, the Centers for Medicare & Medicaid Services (“CMS”) released the U.S. Department of Health and Human Services (“HHS”) Notice of Benefit and Payment Parameters for 2024 Final Rule (the “Notice”) that includes standards for issuers and Marketplaces, and requirements for agents, brokers, web-brokers and others. The Notice implements various changes previously proposed by CMS, including (i) requiring provider networks to comply with network adequacy standards and delaying the implementation of appointment wait time standards, (ii) standardizing plan options, (iii) adding special enrollment periods to increase ease of obtaining coverage, (iv) strengthening markets, and (v) bolstering program integrity.Continue Reading CMS Releases Notice of Benefit and Payment Parameters for 2024 Final Rule