C&M Health Law

C&M Health Law

Analysis, commentary, and the latest developments in health care law and policy

Chris Cadena

Chris Cadena

Chris Cadena is an associate in Crowell & Moring’s San Francisco office and practices in the Litigation and Health Care groups.

Chris earned his J.D. in 2012 from the UCLA School of Law, where he was the chief managing editor of the Chicano–Latino Law Review and a writing advisor for the school’s Lawyering Skills course. While attending law school, Chris was an extern for the California Department of Justice, Attorney General’s Office in Oakland. Chris graduated with honors from UC Berkeley, earning his B.A. in history.

Read Chris's bio on Crowell & Moring's website

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CMS Proposed Rule Implements Mental-Health Parity Requirements for Medicaid Managed Care and CHIP Plans

Posted in Medicaid, Mental Health Parity
On April 6, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule to implement the 2008 Mental Health Parity and Addiction Equity Act (“MHPAEA”) for coverage offered by Medicaid Managed Care Organizations (“MCOs”), Medicaid Alternative Benefit Plans (“ABPs”) and the Children’s Health Insurance Program (“CHIP”).  MHPAEA requires group health plans and health… Continue Reading

Study Suggests Many ACA Exchange Plans Violate Federal Parity Laws

Posted in Employee Benefits, Health Care Reform & ACA, Mental Health Parity
According to a new study focusing on consumer information, nearly 25 percent of group health plans provided through Affordable Care Act (“ACA”) exchanges may be violating federal mental-health parity laws. The study was led by associate professor Colleen Barry of the Johns Hopkins Bloomberg School of Public Health, and is published in the current issue… Continue Reading

OMB: Weak Oversight to Blame for Healthcare.gov Woes

Posted in Exchanges, Health Care Reform & ACA
On March 4, 2015, The U.S. Government Accountability Office (GAO) released a report on the troubled rollout of Healthcare.gov. The GAO concluded that weak oversight by the federal Office of Management and Budget (OMB) may have contributed to the technology problems associated with the Healthcare.gov project. In one example of poor oversight, the GAO noted… Continue Reading

Proposed Rule Would Broaden Rights for Same-Sex Couples at U.S. Hospitals

Posted in Medicaid, Medicare
On December 12, 2014, the Centers for Medicare & Medicaid Services (CMS) announced a proposed rule that would broaden rights for same-sex spouses at US hospitals. The proposed rule is aimed at “ensur[ing] that same-sex spouses in legally-valid marriages are recognized and afforded equal rights in Medicare and Medicaid participating facilities.” In its 2013 decision… Continue Reading

CMS Issues Final Rule on ACA Marketplace Enrollment

Posted in Exchanges, Health Care Reform & ACA
On September 2, 2014, the Centers for Medicare & Medicaid Services (CMS) announced a Final Rule specifying enrollment notice requirements and re-enrollment options for plans offered through the Exchange in 2015. Regarding notice requirements, the Final Rule states that consumers in the Exchange will receive notices from the marketplace before open enrollment begins that explain… Continue Reading

Secretary Burwell Announces Changes Regarding Management and Accountability for the 2015 Open Enrollment Period

Posted in Exchanges, Health Care Reform & ACA
On June 20, 2014, Health and Human Services Secretary Sylvia Burwell announced management changes intended to improve the implementation of the Affordable Care Act. The changes are being implemented in response to the rollout of Healthcare.gov and recommendations submitted to the Secretary. Andy Slavitt will join the Centers for Medicare and Medicaid Services (CMS) as… Continue Reading

CMS Issues Proposed Rule Regarding Exchange and Insurance Market Standards for 2015 and Beyond

Posted in Exchanges, Health Care Reform & ACA
On March 17, 2014, the Centers for Medicare and Medicaid Services (CMS) issued for public inspection a proposed rule regarding the Exchange and Insurance Market Standards for 2015 and later years. The proposed rule addresses requirements under the Affordable Care Act (ACA) applicable to insurance issuers, exchanges, and other entities.… Continue Reading

CMS Issues Final Notice Regarding Payment Parameters for 2015

Posted in Exchanges, Health Care Reform & ACA
The Centers for Medicare and Medicaid Services (CMS) published its final Notice of Benefit and Payment Parameters for 2015 (Final Rule), altering parameters for premium stabilization programs established by the Affordable Care Act (ACA). The Final Rule primarily concerns the risk adjustment, reinsurance, and risk corridors programs. The Final Rule completes provisions related to the… Continue Reading

CMS Amends CLIA and HIPAA to Provide Individuals with Greater Access to Health Information

Posted in HIPAA & Privacy
On February 6, 2014, the Centers for Medicare and Medicaid Services (CMS) released a new rule, effective April 7, 2014, amending the Clinical Laboratory Improvement Amendments of 1988 (CLIA) regulations and the HIPAA Privacy Rule. The new rule specifies that, at the request of a patient, laboratories subject to CLIA may provide the patient, or… Continue Reading

CMS Issues Proposed Rule Regarding ACA Exchanges’ Financial Integrity and Oversight

Posted in Exchanges, Health Care Reform & ACA
On September 19, 2013, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule regarding financial integrity and oversight standards with respect to Affordable Care Act Insurance Exchanges. As of January 1, 2014, Affordable Insurance Exchanges (“Exchanges”) can make available private health insurance coverage for qualified individuals and employers. This proposed rule outlines… Continue Reading

CMS Issues Guidance on Alternative SHOP Applications

Posted in Exchanges, Health Care Reform & ACA
On August 9, 2013, the Centers for Medicare and Medicaid Services (CMS) released guidance on State Alternative Applications for Health Coverage through the Small Business Health Options Program (SHOP). Beginning October 1, 2013, the new SHOP marketplaces will use applications to determining eligibility for participation in SHOP and enrollment in qualified health plans through the… Continue Reading

CMS Releases FAQ Regarding CCIIO Assessment Fees

Posted in Exchanges, Health Care Reform & ACA
On July 10, 2013, the Center for Medicare and Medicaid Services (CMS) released a “Frequently Asked Question” response regarding CCIIO assessment fees. The question asked “Can States collect assessment fees in their first year of Exchange operations for use in the second year of operations?” The response explained that States can decide to collect assessment… Continue Reading

CMS Issues Final Rule Amending Regulations in the Small Business Health Options Program

Posted in Exchanges, Health Care Reform & ACA, Medicaid
The Centers for Medicare and Medicaid Services (CMS) issued a final rule on May 31, 2013, effective July 31, 2013, regarding the Small Business Health Options Program (SHOP) under the Affordable Care Act (ACA). The ACA permits individuals and small businesses to purchase private health insurance through Health Insurance Marketplaces; section 1311(b)(1)(B) of the ACA… Continue Reading

CMS Issues FAQ Guidance on Reporting Fixed Indemnity Policies

Posted in Health Care Reform & ACA
On May 30, 2013, the Centers for Medicare and Medicaid Services (CMS) issued a “Frequently Asked Questions” document regarding MLR Reporting Requirements. The new question addresses so-called “fixed indemnity” policies that fail to meet the criteria for fixed indemnity policies under the Affordable Care Act Implementation FAQs from January 2013. The question asked whether issuers… Continue Reading