Jeremy Earl

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  Jeremy Earl focuses his practice on providing complex regulatory counseling and advice to a variety of health care organizations such as health insurers, health maintenance organizations, pharmacy benefit managers, health care providers and other industry stakeholders on federal and state regulatory matters. He also drafted and negotiated numerous value-based provider reimbursement agreements on behalf of managed care entities and health care providers such as accountable care organizations (ACOs), health systems and health insurers. Jeremy has been quoted in trade and national publications, including HealthPayer Intelligence, Modern Healthcare, Managed Care Executive, Business Insurance and Vox.com. Read Jeremy Earl's full bio.

How Telehealth Adoption May Drive Increase in Value-Based Care


By and on Jul 20, 2022
Posted In Benefit Controversies, Digital Health, Employee Benefits, Health and Welfare Plans

The COVID-19 pandemic has ushered in significant changes to the healthcare industry, specifically the transition from a fee-for-service model to a value-based care model, and digital health has proved to be a driver of value-based care models. In this Westlaw Today article, McDermott Partners Marshall E. Jackson, Jr. and Jeremy Earl suggest that increased use...

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CMS Aims to Stabilize Exchanges but Does Not Address Issuers’ Biggest Questions


By , and on May 16, 2017
Posted In Health and Welfare Plans

CMS recently released a final rule with the goal of stabilizing Exchange markets for 2018. The agency also issued several significant guidance documents where CMS extended the deadlines for 2018 rate and Exchange qualified health plan application submissions, adopted a good faith compliance standard for 2018 and delegated additional plan certification responsibilities to states. While...

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Trump Administration Takes First Steps to Support Exchanges, but Key Questions Remain


By , and on Mar 2, 2017
Posted In Health and Welfare Plans

In an effort to stabilize the Exchanges and encourage issuer participation, the Centers for Medicare & Medicaid Services (CMS) recently extended the federal Exchange application and rate filing deadlines and published a proposed rule affecting the individual health insurance market and the Exchanges. While issuers will likely see these actions as encouraging signs of the...

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How Congress, President-Elect Trump Might Proceed on Promise to Repeal, Replace ACA


By , and on Nov 14, 2016
Posted In Health and Welfare Plans

President-elect Donald Trump has vowed to repeal and replace the Affordable Care Act (ACA). This campaign promise, which echoes a familiar refrain from Republicans since ACA’s passage, is more complex than it may seem. There are pathways to quickly “repealing” key elements of ACA such as the individual mandate and its subsidies, but this could...

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King v. Burwell Decision Upholds Subsidies in Federal Exchanges


By , , and on Jul 2, 2015
Posted In Benefit Controversies, Employee Benefits, Fiduciary and Investment Issues, Health and Welfare Plans, Labor

On June 25, 2015, the Supreme Court of the United States ruled in King v. Burwell that the Affordable Care Act (ACA) requires premium tax credits to be made available in states that use a federal exchange. The case challenged an Internal Revenue Service (IRS) regulation allowing tax credits in federal exchanges. The Supreme Court upheld the...

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2015 Notice of Benefit and Payment Parameters


By , and on Apr 3, 2014
Posted In Health and Welfare Plans

The Centers for Medicare & Medicaid Services’ Final Notice of Benefit and Payment Parameters for 2015 contains numerous alterations to premium stabilization programs, cost-sharing requirements and employee counting provisions to account for lower-than-anticipated enrollment through the Exchanges and the Obama Administration’s decision to permit individuals to “keep their current plan” through 2016.  All of these...

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