Kevin G. Fitzgerald

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In our blog post of July 10, 2018, we discussed the key elements of the Final Rule issued on June 21, 2018 with respect to Association Health Plans (AHPs). As we noted, the expansion of ERISA’s definition of an employer and the other elements of the Final Rule designed to expand insurance opportunities for small employers, including sole proprietorships had been opposed by a variety of interests, including the Attorneys General of a number…
Background Health Plans and health care providers are getting into each other’s business.  This payor/provider convergence has taken different forms.  Health systems have ventured into the health insurance business by acquiring or starting their own health plans and by establishing joint ventures with payors, to jointly own and operate a health plan.  Health plans have also moved into the health care provider business by acquiring hospitals, surgery centers, medical groups, and other providers.  This blog…
The Iowa Commissioner of Insurance (the “Commissioner”) filed a petition, on January 29, 2015, seeking to liquidate CoOpportunity Health, Inc. (“CoOpportunity”), a Consumer Operated and Oriented Plan (“CO-OP”) established under the Affordable Care Act (“ACA”) that has sold health insurance on the Iowa and Nebraska Exchanges. This planned liquidation follows the rehabilitation order with respect CoOpportunity in December, which we discussed in a prior blog post. If the petition is granted—and we fully…
The Iowa Insurance Commissioner obtained an Order for Rehabilitation with respect to CoOportunity Health, Inc. (“CoOportunity”) on December 24, 2014. With the Rehabilitation Order, the Iowa Insurance Commission took possession of CoOportunity’s assets and will administer CoOportunity under the general supervision of the Iowa District Court. The Iowa Insurance Commissioner has indicated that it is currently evaluating the totality of CoOportunity’s situation and the full impact of the rehabilitation. It has issued initial guidance to…