I recently talked to HHS regarding an annual limit waiver (i.e., mini-med waiver) that i filed on behalf of a client. HHS requested additional information, which is not new. But, what is new, is that one of the additional pieces of requested information is a hypothetical calculation of premiums for the next year, assuming that the plan sponsor had to raise the annual limit to $750,000. Theoretically, this sounds like good information for HHS to request. But, this information takes time to produce and is not included in any of the HHS guidance regarding the waiver application process. Anyone filing a new waiver application should include this additional information from the start, because HHS said they will request this of every applicant in the future.
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.