In April 2024, the Department of Health and Human Services (HHS) finalized revised regulations implementing Section 1557 of the Patient Protection and Affordable Care Act (ACA). The new, final Section 1557 regulations (2024 Rule) have staggered effective dates—beginning as early as November 2, 2024—and the 2024 Rule now applies to recipients of Medicare Part B payments. In this article, we discuss some notable changes in the 2024 Rule and provide a chart summarizing key requirements and compliance deadlines.

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Photo of Doug Dahl Doug Dahl

Doug Dahl provides technical knowledge and advice to companies on a wide range of federal tax and ERISA matters regarding employee benefits, including qualified retirement plans, executive compensation arrangements and health and welfare plans. Doug regularly assists companies with employee benefit issues that…

Doug Dahl provides technical knowledge and advice to companies on a wide range of federal tax and ERISA matters regarding employee benefits, including qualified retirement plans, executive compensation arrangements and health and welfare plans. Doug regularly assists companies with employee benefit issues that arise during and following various corporate transactions and events, such as mergers, acquisitions, dispositions and bankruptcies.

Photo of Catherine Simpson Catherine Simpson

Catherine Simpson works with clients on the design, administration, and compliance of qualified benefit plans, health and welfare benefit plans, and deferred compensation packages. She also provides diligence and support on employee benefits and compensation issues arising in corporate transactions.

Photo of Angela Humphreys Angela Humphreys

As chair of the Healthcare Practice Group and co-chair of the Healthcare Private Equity Team, Angela Humphreys leads the firm’s national healthcare practice. With more than 20 years of experience, she has counseled national healthcare organizations on hundreds of transactions in the healthcare…

As chair of the Healthcare Practice Group and co-chair of the Healthcare Private Equity Team, Angela Humphreys leads the firm’s national healthcare practice. With more than 20 years of experience, she has counseled national healthcare organizations on hundreds of transactions in the healthcare industry, including hospitals and health systems, health plans, surgery centers, physician practice management companies, dental service organizations, laboratories and healthcare information technology companies, among others. She also leads interdisciplinary teams to provide clients with creative solutions to the operational and regulatory issues they face while working within an ever-changing, complex regulatory environment.