Emily Curran
Subscribe to Emily Curran's PostsEmily R. Curran focuses her practice on healthcare regulatory and compliance issues in the managed care space. She counsels both for-profit and non-profit healthcare insurance companies on state and federal policy issues and advises clients on reimbursement issues that come into play when participating in government healthcare programs. Emily also supports the Firm’s transactional work. Read Emily Curran's full bio.
State Regulators Address Insurers’ Use of AI: 11 States Adopt NAIC Model Bulletin
By Gregory Mitchell and Emily Curran on Jun 25, 2024
Posted In Digital Health, Health and Welfare Plans
In December 2023, the National Association of Insurance Commissioners (NAIC) adopted a Model Bulletin on the Use of Artificial Intelligence (AI) Systems by Insurers. The model bulletin reminds insurance carriers that they must comply with all applicable insurance laws and regulations (e.g., prohibitions against unfair trade practices) when making decisions that impact consumers, including when...
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340B Remedy Rule and Medicare Advantage Rates: Navigating Shifting Payments
By Emily J. Cook and Emily Curran on May 7, 2024
Posted In Employee Benefits, Health and Welfare Plans
On April 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the Announcement of Calendar Year (CY) 2025 Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies, otherwise known as the rate announcement. The rate announcement is released annually and includes updates to the methodologies used to calculate MA plan payments,...
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CMS Releases CY 2025 Advance Notice for Medicare Advantage and Part D
By Emily Curran and Kristen O'Brien on Mar 21, 2024
Posted In Employee Benefits, Health and Welfare Plans
On January 31, 2024, the US Centers for Medicare & Medicaid Services (CMS) released the Advance Notice of Methodological Changes for Calendar Year (CY) 2025 for Medicare Advantage (MA) Capitation Rates and Part C and D Payment Policies. CMS also released a press release and fact sheet. The advance notice is released on an annual basis and includes proposed updates...
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An Update on the No Surprises Act
By Jeffrey Davis, Kristen O'Brien and Emily Curran on Sep 28, 2023
Posted In Employee Benefits, Health and Welfare Plans
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CMS Issues Broad-Ranging Medicare Advantage and Part D Proposed Rule
By Ankur J. Goel, Emily Curran, Grayson I. Dimick and Casey Li on Feb 21, 2023
Posted In Employee Benefits, Health and Welfare Plans
The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule regarding Contract Year 2024 Policy and Technical Changes to the Medicare Advantage (MA) and Medicare Prescription Drug Benefit Programs. This proposed rule includes a range of proposals addressing popular topics, including marketing and prior authorization, along with other significant changes to utilization...
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Departments Issue Final Rule Implementing Certain No Surprises Act Provisions
By Brian Stimson, Jamie Gelfman, Drew Elizabeth McCormick and Emily Curran on Sep 14, 2022
Posted In Employee Benefits, Health and Welfare Plans
On August 19, 2022, the US Departments of Health and Human Services (HHS), Labor and Treasury posted a final rule revising portions of the federal No Surprises Act (NSA). Generally, the rule finalizes three aspects of the two-part interim final rule that the Departments published along with the Office of Personnel Management in 2021. First,...
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Proposed Rule on MA and Part D Would Reinstate Historical Requirements, Make Changes to Prescription Drug Payment Structure
By Kate McDonald, Mara McDermott, Ankur J. Goel, Emily Curran, Taylor Hood and Haile Dagne on Mar 3, 2022
Posted In Employee Benefits, Health and Welfare Plans
On January 6, 2022, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule regarding Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs, marking the Biden administration’s first proposed rule on these topics. The proposed rule includes proposed changes to the manner in which...
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