Update for January 3, 2013 · 2013. 10. 3. · The law adds non-mail order diabetic supplies, including testing strips, to the Medicare DMEPOS competitive bidding program. H.R. 8

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Congress Passes ‘Cliff’ Legislation, Delays Sequestration and Extends Medicare Provisions

The House and Senate have

passed a tax relief bill that also delays

a cut in Medicare payments to

physicians until the end of the year.

The American Taxpayer Relief Act

(HR 8) permanently extends current

tax rates for those earning up to

$400,000 (up to $450,000 for married

filing jointly) that were scheduled to

expire at the end of 2012 as part of

the “fiscal cliff.” The across-the-

board budget cuts that were included

in the Budget Control Act of 2011

sequestration that were scheduled to

take effect on January 2 will be www.polsinelli.com

delayed for two months. In addition

to the “doc fix,” the law extended a

number of expiring Medicare

provisions. The following are some

of the major Medicare extenders and

other health provisions of H.R. 8:

� The law extends the current

Medicare physician payment

rates through December 31,

2013, canceling the 26.5

percent reduction that was

scheduled for January 1,

2013.

� Under current law, the

Medicare fee schedule is

adjusted geographically for

three factors that reflect

Update for January 3, 2013

Top News ….. 1

State News ….. 4

Regulatory News ….. 4

Additional Reading …..6

Federal Register ….. 7

For More Information ….. 11

Top News

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

© 2013 Polsinelli Shughart Page 2 of 14

differences in the cost of resources needed to

produce physician services. H.R. 8 extends the

existing 1.0 floor on the “physician work” factor

through December 31, 2013.

� The law extends the exceptions process for

outpatient therapy services through December 31,

2013. For physical therapy and speech-language

pathology services combined, the limit on

incurred expenses is $1,900 in 2013. For

occupational therapy services, the limit in 2013 is

$1,900. However, an exceptions process has

been in place for care that is determined to be

medically necessary. The exceptions process

was scheduled to expire at the end of 2012. H.R.

8 extends the exceptions process for another year.

The law also extends the cap on the services

received in critical access hospital outpatient

departments through the end of 2013.

� The law extends the add-on payment for ground

ambulance transports in “super-rural” areas

through December 31, 2013, and for air

ambulance transports until June 30, 2013.

� Add-on payments for qualifying low-volume

hospitals are extended until the end of 2013.

� The Medicare Dependent Hospital program,

which supports small rural hospitals, is extended

until October 1, 2013.

� The law reauthorizes Medicare Advantage

special needs plans through 2014. These plans

are permitted to target enrollment to

institutionalized beneficiaries, dual-eligibles,

and individuals with severe or disabling

chronic conditions.

� The law extends the Qualifying Individual

program until December 31, 2013. The

program allows Medicaid to pay the Medicare

Part B premiums for Medicare beneficiaries

with incomes between 120 percent and 135

percent of the federal poverty level.

� The law adds non-mail order diabetic supplies,

including testing strips, to the Medicare

DMEPOS competitive bidding program.

� H.R. 8 extends Transitional Medical Assistance

for one year (through December 31,

2013).Delaying the cut in Medicare physician

payments and extending the other Medicare

payment policies is estimated to cost about $30

billion. The law offsets the cost of the delay

through various Medicare and Medicaid

offsets, including phasing in the recoupment of

past overpayments to hospitals made as a result

of the transition to Medicare Severity

Diagnosis Related Groups; rebasing the

Medicaid Disproportionate Share Hospital

(DSH) payments; reducing payment for

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

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Community Pharmacists said that many pharmacists

may be forced to stop providing the products.

Tennessee Senators Propose “Dollar-for-Dollar” Deficit Reduction Plan

On December 28, Tennessee Senators Bob Corker

(R) and Lamar Alexander (R) proposed a “Dollar-for-

Dollar” plan that would reduce the growth of

entitlement spending by almost $1 trillion in exchange

for a $1 trillion increase in the debt ceiling. The plan

would reduce the growth of spending in Medicare by

$689 billion, reduce Medicaid spending by $50 billion,

and reduce Social Security spending by $62 billion.

Under the plan, starting in November 2016, seniors

could choose either traditional Medicare or a “Total

Health Plan” that would cover Medicare Parts A, B,

and D. Packages could include standard health benefits

with access to negotiated prices or an alternative

package that includes actuarially equivalent coverage.

It would allow states more flexibility to manage their

Medicaid programs, reform Social Security and

gradually raise the retirement age. While this approach

was not adopted in H.R. 8, elements could resurface

during budget and debt ceiling negotiations that are

expected in the next two months. The bill, S. 3673, the

“Dollar-for-Dollar Act,” is available here. A summary

multiple therapies provided on the same day;

rebasing end-stage renal disease payments;

adjusting coding intensity for Medicare

Advantage plans; eliminating unobligated funds

from the health reform law’s Consumer Operated

and Oriented Plans; and reducing payments for

advanced imaging services. The American

Hospital Association said it was “very

disappointed” that the law may jeopardize

hospitals’ ability to provide care. In response to

the addition of non-mail order diabetic supplies

to the competitive bidding program, the National

Association of Community Pharmacists said that

many pharmacists may be forced to stop

providing the products.

Delaying the cut in Medicare physician payments and

extending the other Medicare payment policies is

estimated to cost about $30 billion. The law offsets the

cost of the delay through various Medicare and Medicaid

offsets, including phasing in the recoupment of past

overpayments to hospitals made as a result of the

transition to Medicare Severity Diagnosis Related

Groups; rebasing the Medicaid Disproportionate Share

Hospital (DSH) payments; reducing payment for multiple

therapies provided on the same day; rebasing end-stage

renal disease payments; adjusting coding intensity for

Medicare Advantage plans; eliminating unobligated

funds from the health reform law’s Consumer Operated

and Oriented Plans; and reducing payments for advanced

imaging services. The American Hospital Association

said it was “very disappointed” that the law may

jeopardize hospitals’ ability to provide care. In response

to the addition of non-mail order diabetic supplies to the

competitive bidding program, the National Association of

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

© 2013 Polsinelli Shughart Page 4 of 14

Minnesota Approved for State-Based Exchange

Minnesota has received conditional approval from

HHS to operate a state-run health insurance exchange.

Insurers in the state are worried there is not enough

time to “revamp” their policies to comply with the

requirements. No individual health insurance product

in the state currently complies with the law, according

to Dannette Coleman of Medica, an insurer based in

Minnetonka. “We literally are going to be required to

revamp all of our products, rewrite all of our contracts

that our members receive; re-price everything; and we

still don't have all of the answers that we need to do that

work,” Coleman said. Insurers interested in selling

policies on the exchanges must submit their plans to the

state no later than May 17, and those plans must be

ready to begin accepting enrollment by October 1,

2013.

Regulatory News

IRS Issues Proposed Rule on Employers’

Obligations Regarding Minimum Essential Health

Coverage

The IRS published a notice of proposed rulemaking

on the shared responsibility for employers regarding

of the proposal is available here.

New England Compounding Center Files for

Bankruptcy

The New England Compounding Center, the

compounding pharmacy responsible for the fungal

meningitis outbreak that resulted in 620 infections and 39

deaths has filed for bankruptcy protection under Chapter

11 of the U.S. Bankruptcy Code. The company said in its

filing that it seeks to establish a fund for the individuals

and families of those affected to provide a “greater,

quicker, and fairer payout” to its creditors than they could

achieve through piecemeal legislation. Additional

details are available here.

State News

Colorado Likely to Expand Medicaid

Colorado Governor John Hickenlooper indicated

recently that he likely will support expanding Medicaid,

at a cost estimated to reach as much as $858 million over

the next 10 years. Medicaid funding in Colorado

represents about one-quarter of the state’s general fund

and would stay flat from 2012-13 to the new budget year

in 2013-14. Overall expenditures would be $5.6 billion,

with $2.8 billion coming from the federal government.

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

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CMS Releases HVBP Performance Ratings

CMS announced quality bonuses and penalties for

nearly 3,000 hospitals beginning in January 2013 under

the Hospital Value-Based Purchasing Program

(HVBP). Under this program, CMS makes incentive

payments to hospitals based on how well they perform

on each measure or how much they improve their

performance on each measure compared to their

performance on the measure during a baseline

performance period. CMS announced that it will

reward 1,557 hospitals for improvements in quality

ratings and reduce payments to 1,427 others. The

penalties are impacting some types of hospitals more

than others. Larger hospitals, teaching hospitals, and

disproportionate share hospitals fared worse than

smaller hospitals. Additional details regarding the

Hospital Value-Based Purchasing Program are

available here.

Insurers Push for Increased Enrollment Incentives

Two of the nation’s largest health insurer groups told

CMS that strong incentives need to be in place to

prevent people from delaying enrollment in health

insurance plans. America’s Health Insurance Plans

(AHIP) and the Blue Cross Blue Shield Association

(BCBSA), in comments on HHS’ proposed rule on

employee health coverage. These proposed regulations

would affect only employers that meet the definition of

“applicable large employer.” An applicable large

employer with respect to a calendar year is defined as an

employer that employed an average of at least 50 full-

time employees on business days during the preceding

calendar year. This notice is intended to provide

employers with guidance pending the issuance of final

regulations or other applicable guidance. The notice

announces an upcoming public hearing that will be held

on April 23, 2013 in Washington, DC (preregistration

required). Comments will be accepted until March 18,

2013. The notice, available here, appeared in the January

2 Federal Register.

CMS Issues Guidance for MAGI Conversion

CMS recently released guidance to states to assist

them as they begin to plan converting current net income

eligibility thresholds to equivalent modified adjusted

gross income (MAGI) thresholds in the Medicaid

program and the Children’s Health Insurance Program

(CHIP). The guidance outlines the conversion

methodology, process and timeframes for executing the

conversions. Beginning on January 1, 2014, a

methodology for determining income based on MAGI

will apply to both Medicaid and CHIP eligibility for most

enrollees, including children, pregnant women, parents

and caretaker relatives, and the new adult group. This

new methodology is aligned with the system that will be

used to determine eligibility for the premium tax credits

and cost sharing reductions available to certain

individuals purchasing coverage on the exchanges. The

guidance is available here.

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

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00100) Comparison of Second-Quarter 2012

Average Sales Prices and Average Manufacturer

Prices: Impact on Medicare Reimbursement for

Fourth Quarter 2012

• Kaiser Commission on Medicaid and the

Uninsured: How Much Will Medicaid Physician

Fees for Primary Care Rise in 2013? Evidence from

a 2012 Survey of Medicaid Physician Fees

• Kaiser Family Foundation: Medicaid's Role for

Women Across the Lifespan: Current Issues and

the Impact of the Affordable Care Act

• Kaiser Health News: Florida Facing Huge

Medicaid, 'Obamacare' Decisions in 2013

• Kaiser Health News: When Employers' Health

Plans Disappear, Workers Often Have Few Options

• Los Angeles Times: Medical Field Works to

Reduce Number of Surgical Mistakes

• New York Times: One Boy's Death Moves State to

Action to Prevent Others

• New York Times: Doctors Warned on 'Divided

Loyalty'

• St. Louis Beacon: General Assembly Returns With

New Leadership and Full Agenda

health insurance market reforms, said that surcharges for

delayed enrollment and limited coverage options should

be considered for individuals who do not sign up for

coverage as soon as the health reform provisions are

implemented in 2014. They said that without strong

incentives to encourage everyone to enroll at the outset,

people could obtain coverage only when they need it and

drop it when they do not, which would drive up costs for

everyone. “Additional strategies are necessary to

encourage participation, minimize disruption, and

mitigate rate shock” when the primary reforms of the

Affordable Care Act begin in 2014, AHIP said in its

comment letter. The two groups proposed restricting late

enrollees to the lowest level of coverage – the “bronze”

plan, which limits coverage at 60 percent of medical

expenses. The two groups also called on HHS to allow

states the option of phasing in the ACA’s requirement

that older adults pay no more than three times what

younger adults pay in 2014 and 2015 in the individual

and small group markets. Comment letters are available

here.

Additional Reading

• American Medical News: ED Use Drops When

Medical Practices Extend Office Hours

• Government Accountability Office: Report: Private-

Sector Initiatives Can Help Inform CMS Quality and

Efficiency Incentive Efforts

• Office of the Inspector General: Report (OEI-16-11-

00081): Limited Supplier Solicitation of Prescribing

Physicians Under Medicare DMEPOS Competitive

Bidding Program

• Office of the Inspector General: Report (OEI-03-13-

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

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Federal Register

AHRQ published a notice that a proposed collection of information project entitled “Medical Expenditure Panel

Survey – Insurance Component” has been submitted to the OMB for review and approval. Comments will be accepted

for 60 days following publication. The notice, available here, appeared in the December 26 Federal Register.

CDC published a notice that a proposed collection of information project entitled “Early Hearing Detection and

Intervention – Pediatric Audiology Links to Service Facility Survey” has been submitted to the OMB for review and

approval. Comments will be accepted for 30 days following publication. The notice, available here, appeared in the

December 28 Federal Register.

CDC published a notice announcing an upcoming public meeting of the Interagency Committee on Smoking and

Health. The meeting will be held on January 29, 2013 in Washington, DC. The notice, available here, appeared in the

December 31 Federal Register.

CMS published a notice that a proposed collection of information project entitled “Medicaid and CHIP Program

(MACPro)” has been submitted to the OMB for review and approval. Comments will be accepted for 30 days following

publication. The notice, available here, appeared in the December 21 Federal Register.

CMS published a notice that a proposed collection of information project entitled “The Fiscal Soundness Reporting

Requirements” has been submitted to the OMB for review and approval. Comments will be accepted for 30 days

following publication. The notice, available here, appeared in the December 21 Federal Register.

CMS published a notice that a proposed collection of information project entitled “Medicare Enrollment

Application for Clinics/Group Practice and Certain Other Suppliers” has been submitted to the OMB for review and

approval. Comments will be accepted for 30 days following publication. The notice,

available here, appeared in the December 21 Federal Register.

CMS published a notice entitled “Hospital and Vendor Readiness for Electronic

Health Records Hospital Inpatient Quality Data Reporting” that solicits information

from hospitals, electronic health record (EHR) vendors, and other interested parties

regarding hospitals’ readiness to electronically report certain patient-level data under

the Hospital Inpatient Reporting Program using the Quality Reporting Document

Architecture Category 1. CMS is interested in increasing efficiency and reducing the

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

© 2013 Polsinelli Shughart Page 8 of 14

burden associated with hospital collection and submission of patient-level data on clinical quality measures and is

exploring ways that hospitals might be able to report data on a subset of Hospital Inpatient Quality Reporting Program

measures using the same certified electronic health record technology that is used for reporting under the EHR Incentive

Program. To ensure consideration, comments must be received no later than January 22, 2013. The notice, available

here, is scheduled to appear in the January 3 Federal Register.

CDC published a notice that a proposed collection of information project entitled “The National HIV Surveillance

System” has been submitted to the OMB for review and approval. Comments will be accepted for 30 days following

publication. The notice, available here, appeared in the December 24 Federal Register.

CDC published a notice announcing an upcoming meeting of the Health Disparities Subcommittee. The meeting

will be held on January 23, 2013 via telephone conference. The notice, available here, appeared in the December 24

Federal Register.

CDC published a notice that a proposed collection of information project entitled “Well-Integrated Screening and

Evaluation for Women Across the Nation (WISEWOMAN)” has been submitted to the OMB for review and approval.

Comments will be accepted for 30 days following publication. The notice, available here, appeared in the December 26

Federal Register.

CDC published a notice that a proposed collection of information project entitled “Laboratory Response Network”

has been submitted to the OMB for review and approval. Comments will be accepted for 60 days following publication.

The notice, available here, appeared in the January 3 Federal Register.

CDC published a notice that a proposed collection of information project entitled “National HIV Prevention

Program Monitoring and Evaluation” has been submitted to the OMB for review and approval. Comments will be

accepted for 30 days following publication. The notice, available here, appeared in the

January 3 Federal Register.

CDC published a notice that a proposed collection of information project entitled

“CDC Oral Health Management Information System” has been submitted to the OMB

for review and approval. Comments will be accepted for 30 days following

publication. The notice, available here, appeared in the January 3 Federal Register.

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FDA published a notice that a proposed collection of information project entitled “Experimental Study: Corrective

Direct-to-Consumer Television Advertising” has been submitted to the OMB for review and approval. Comments will be

accepted for 30 days following publication. The notice, available here, appeared in the December 24 Federal Register.

FDA published a notice announcing an upcoming public workshop entitled “Public Workshop on Minimal Residual

Disease.” The workshop will be held on March 4, 2013 at the FDA White Oak Campus in Silver Spring, MD. The

notice, available here, appeared in the December 24 Federal Register.

FDA published a notice announcing an upcoming public workshop entitled “Public Workshop on Minimal Residual

Disease.” The workshop will be held on February 27, 2013 at the FDA White Oak Campus in Silver Spring, MD. The

notice, available here, appeared in the December 24 Federal Register.

FDA published a notice announcing the availability of draft guidance entitled “Draft Revision of Guidance for

Industry on Providing Regulatory Submissions in Electronic Format--Certain Human Pharmaceutical Product

Applications and Related Submissions Using the Electronic Common Technical Document Specifications.” To ensure

consideration, comments must be received no later than 60 days following publication. The notice, available here,

appeared in the January 3 Federal Register.

FDA published a notice announcing an upcoming public hearing and extension of comment period entitled “Food

and Drug Administration Actions Related to Nicotine Replacement Therapies and Smoking-Cessation Products; Reports

to Congress on Innovative Products and Treatments for Tobacco Dependence.” The FDA is extending the comment

period for the notice of public hearing that appeared in the Federal Register of November 28, 2012 (77 FR70955). The

comment period has been extended to January 16, 2013. The notice, available here, appeared in the January 3 Federal

Register.

HHS published a direct final rule and request for comments entitled “Control of

Communicable Diseases: Foreign; Scope and Definitions.” This final rule allows the

CDC and HHS to update and reorganize the scope and definitions for foreign

quarantine regulations and adds a new section containing definitions for importations.

Comments will be accepted until January 25, 2013. The rule becomes effective on

February 25, 2013. The notice, available here, appeared in the December 26 Federal

Register.

HHS published a direct final rule and request for comments entitled “Control of

Communicable Diseases: Interstate; Scope and Definitions.” This final rule will allow

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

© 2013 Polsinelli Shughart Page 10 of 14

communicable diseases that require quarantine. Comments will be accepted until January 25, 2013. This final rule

becomes effective on February 25, 2013. The notice, available here, appeared in the December 26 Federal Register.

HHS published a notice announcing an upcoming public meeting of the Presidential Commission for the Study of

Bioethical Issues. The meeting will be held January 14-15, 2013 in Miami, FL. Submission of written comments is

encouraged. The notice, available here, appeared in the December 26 Federal Register.

HHS published a notice that a proposed collection of information project entitled “Evaluation of the National for

Action to End Health Disparities” has been submitted to the OMB for review and approval. Comments will be accepted

for 30 days following publication. The notice, available here, appeared in the December 28 Federal Register.

HHS’ Office of the Inspector General published a notice soliciting proposals and recommendations for developing

new and modifying existing safe harbor provisions under the federal anti-kickback statute (section 1128B(b) of the Social

Security Act), as well as developing new OIG Special Fraud Alerts. Comments will be accepted for 60 days following

publication. The notice, available here, appeared in the December 28 Federal Register.

HRSA published a notice that a proposed collection of information project entitled “Survey of Eligible Users of the

National Practitioner Data Bank and the Healthcare Integrity and Protection Data Bank” has been submitted to the OMB

for review and approval. Comments will be accepted for 60 days following publication. The notice, available here,

appeared in the December 26 Federal Register.

HRSA published a notice that a proposed collection of information project entitled “Medicare Rural Hospital

Flexibility Grant Program Performance Measure Determination” has been submitted to the OMB for review and approval.

Comments will be accepted for 60 days following publication. The notice, available here, appeared in the December 31

Federal Register.

NIH published a notice that a proposed collection of information project entitled

“Pediatric Palliative Care Campaign Pilot Survey” has been submitted to the OMB for

review and approval. Comments will be accepted for 60 days following publication. The

notice, available here, appeared in the December 26 Federal Register.

SAMHSA published a notice that a proposed collection of information project

entitled “National Outcome Measures for Substance Abuse Prevention” has been

HEALTH REFORM + RELATED HEALTH POLICY NEWS | E-ALERT January 3, 2013

© 2013 Polsinelli Shughart Page 11 of 14

For questions regarding any of the issues covered in this Alert, please contact:

� Matthew J. Murer | Practice Area Chair | 312.873.3603 | [email protected]

� Colleen M. Faddick | Practice Area Vice-Chair | 303.583.8201 | [email protected]

� Bruce A. Johnson | Practice Area Vice-Chair | 303.583.8203 | [email protected]

� Alan K. Parver | Practice Area Vice-Chair | 202.626.8306 | [email protected]

� Darryl Drevna | Editor | 202.626.8303 | [email protected]

For More Information

Additional Health Care Public Policy Professionals

Julius W. Hobson, Jr. Washington, D.C. 202.626.8354 [email protected]

Harry Sporidis Washington, D.C. 202.626.8349 [email protected]

submitted to the OMB for review and approval. Comments will be accepted for 60 days following publication. The

notice, available here, appeared in the December 26 Federal Register.

HEALTH REFORM + RELATED HEALTH POLICY NEWS | ATTORNEYS January 3, 2013

© 2012 Polsinelli Shughart Page 12 of 14

Jane E. Arnold St. Louis 314.622.6687 [email protected]

Janice A. Anderson Chicago 312.873.3623 [email protected] Douglas K. Anning Kansas City

816.360.4188 [email protected]

Jack M. Beal Kansas City 816.360.4216 [email protected]

Cynthia E. Berry Washington, D.C. 202.626.8333 [email protected] Mary Beth Blake Kansas City 816.360.4284 [email protected] Gerald W. Brenneman Kansas City

816.360.4221 [email protected] Teresa A. Brooks Washington, D.C. 202.626.8304 [email protected] Jared O. Brooner St. Joseph 816.364.2117 [email protected] Anika D. Clifton Denver 303.583.8275 [email protected] Lawrence C. Conn Los Angeles 310.203.5336 [email protected]

Anne M. Cooper Chicago 312.873.3606 [email protected] Lauren P. DeSantis-Then Washington, D.C. 202.626.8323 [email protected] S. Jay Dobbs St. Louis

314.552.6847 [email protected] Thomas M. Donohoe Denver 303.583.8257 [email protected] Cavan K. Doyle Chicago 312.873.3685 [email protected] Meredith A. Duncan Chicago 312.873.3602 [email protected] Erin Fleming Dunlap St. Louis 314.622.6661 [email protected] Fredric J. Entin Chicago 312.873.3601 [email protected] Jennifer L. Evans Denver 303.583.8211 [email protected] T. Jeffrey Fitzgerald Denver 303.583.8205 [email protected] Michael T. Flood Washington, D.C. 202.626.8633 [email protected]

Kara M. Friedman Chicago 312.873.3639 [email protected] Rebecca L. Frigy St. Louis 314.889.7013 [email protected] Asher D. Funk Chicago

312.873.3635 [email protected] Randy S. Gerber St. Louis 314.889.7038 [email protected] Mark H. Goran St. Louis 314.622.6686 [email protected] Linas J. Grikis Chicago 312.873.2946 [email protected] Lauren Z. Groebe Kansas City 816.572.4588 [email protected] Brett B. Heger Dallas 314.622.6664 [email protected] Jonathan K. Henderson Dallas 214.397.0016 [email protected] Margaret H. Hillman St. Louis 314.622.6663 [email protected] Jay M. Howard Kansas City 816.360.4202 [email protected]

Cullin B. Hughes Kansas City 816.360.4121 [email protected] Sara V. Iams Washington, D.C. 202.626.8361 [email protected] George Jackson, III Chicago

312.873.3657 [email protected] Lindsay R. Kessler Chicago 312.873.2984 [email protected] Joan B. Killgore St. Louis 314.889.7008 [email protected] Anne. L. Kleindienst Phoenix 602.650.2392 [email protected] Chad K. Knight Dallas 214.397.0017 [email protected] Sara R. Kocher St. Louis

314.889.7081 [email protected]

HEALTH REFORM + RELATED HEALTH POLICY NEWS | ATTORNEYS January 3, 2013

© 2012 Polsinelli Shughart Page 13 of 14

Dana M. Lach Chicago 312.873.2993 [email protected] Jason T. Lundy Chicago 312.873.3604 [email protected] Ryan M. McAteer Los Angeles

310.203.5368 [email protected] Jane K. McCahill Chicago 312.873.3607 [email protected] Ann C. McCullough Denver 303.583.8202 [email protected] Ryan J. Mize Kansas City 816.572.4441 [email protected] Aileen T. Murphy Denver 303.583.8210 [email protected] Hannah L. Neshek Chicago

312.873.3671 [email protected]

Gerald A. Niederman Denver 303.583.8204 [email protected] Edward F. Novak Phoenix 602.650.2020 [email protected] Thomas P. O’Donnell Kansas City

816.360.4173 [email protected] Aaron E. Perry Chicago 312.873.3683 [email protected] Mitchell D. Raup Washington, D.C. 202.626.8352 [email protected] Daniel S. Reinberg Chicago 312.873.3636 [email protected] Donna J. Ruzicka St. Louis 314.622.6660 [email protected] Charles P. Sheets Chicago

312.873.3605 [email protected]

Kathryn M. Stalmack Chicago 312.873.3608 [email protected] Leah Mendelsohn Stone Washington, D.C. 202.626.8329 [email protected] Chad C. Stout Kansas City

816.572.4479 [email protected] Steven K. Stranne Washington, D.C. 202.626.8313 [email protected] William E. Swart Dallas 214.397.0015 [email protected] Tennille A. Syrstad Denver 312.873.3661 [email protected] Emily C. Tremmel Chicago 303.583.8263 [email protected] Andrew B. Turk Phoenix

602.650.2097 [email protected]

Joseph T. Van Leer Chicago 312.873.3665 [email protected] Andrew J. Voss St. Louis 314.622.6673 [email protected] Joshua M. Weaver Dallas

214.661.5514 [email protected] Emily Wey Denver 303.583.8255 [email protected] Mark R. Woodbury St. Joseph 816.364.2117 [email protected] Janet E. Zeigler Chicago 312.873.3679 [email protected]

HEALTH REFORM + RELATED HEALTH POLICY NEWS | ABOUT January 3, 2013

© 2012 Polsinelli Shughart Page 14 of 14

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