Industries

• Health Care Innovation

Practices

• Corporate Law
• Government Services
• Insurance Regulation & Risk Management

Solutions

• Coronavirus Response Team
• Outside General Counsel Services

Biography

Bill practices administrative and regulatory law in the areas of insurance and health care, representing health insurance and health care companies. With more than 22 years of in-house experience at one of America’s largest health care companies, he has advised licensed and risk-bearing entities in administrative, regulatory, and enforcement matters before state and federal agencies.  Bill managed major in-house law department functions supporting commercial health insurance, Medicare, and Medicaid products and operations, and has extensive knowledge and experience resolving complex legal, regulatory and operational problems for his clients. He works closely to understand their business, providing legal advice that helps them achieve their goals and objectives in an ever-changing legal and regulatory environment.

Bill leads Frost Brown Todd’s Insurance Regulation Practice Group and is a member of the firm’s Insurance Industry Team and Health Care Innovation Team. He is AV rated by Martindale-Hubbell, and a member of the Federation of Regulatory Counsel (FORC) and of the American Health Law Association (AHLA).

Bill’s experience in administrative, regulatory and insurance law includes the following areas:

• Insurance, HMO and other managed care entity licensing, organization and operations
• Life, health, and ancillary product development, including:
  • Individual, small employer and large employer group fully insured health insurance and specialty products (vision, dental, term life, disability income, etc.)
  • Small and large group self-funded, stop loss, and administrative services only products
  • Association group and trust related insurance arrangements, products, and operations
  • Whole and term life insurance and annuity products, including accelerated death benefits to pay for home health and long-term care
  • Risk pooling, rating, reinsurance and related financial requirements
• Pricing and underwriting
• Claims adjudication, customer service and other insurance administration operations
• Clinical, utilization review, medical management and appeals activities
• Healthcare practitioner, provider, lab, and pharmacy network development, adequacy and accessibility requirements
• Regulatory filing and approval requirements for licenses, products, and all insurance and operational activities
• Insurance company holding systems, domestic and foreign
• International medical and travel insurance, covering inpatriates and expatriates, including surplus lines
• Risk-based capital, reserving, and other financial obligations
• Financial and market conduct exams, desk audits, and complaint investigations
• Administrative hearings and enforcement actions and appeals before state and federal agencies and courts
• Protection of confidential, proprietary, trade secrets in regulatory and other filings
• High-risk pools and other reinsurance/risk-sharing arrangements
• HIPAA and GLB privacy and security matters
• ACA requirements, including:
  • Insurance market reforms – guaranteed availability and guaranteed renewability
  • Coverage of preventive care with no cost-sharing, including women’s contraceptives
  • Coverage of dependents up to age 26
  • Rate review, medical loss ratio (MLR), single risk pool, and 3 R’s (risk adjustment, risk corridors and reinsurance)
  • Prohibition on discrimination in eligibility and premiums based on health status-related factors
  • Coverage of essential health benefits (EHBs) and metal level plans (bronze, silver, gold and platinum)
  • Exchange requirements, including qualified health plan certification, participation agreements and subsidies (advanced premium tax credit and cost-sharing reduction)
  • Section 1557 non-discrimination requirements. Individual and employer mandates and associated taxes
  • Excepted benefits – hospital and other fixed indemnity and specified disease and illness plans
  • Short term-limited duration insurance
• Insurance producers, agents and brokers, including:
  • Commissions and other forms of compensation
  • Lead generation arrangements
  • Advanced payment of commissions, including security agreements and perfection of secured interests
  • Captive agents and independent broker arrangements
• Sales, marketing and advertising of insurance brands and products, including:
  • Establishing systems of control over advertising for market conduct compliance
  • Traditional brick and mortar sales operations and virtual presence web-based eAgencies
  • Internal and external distribution channels and lead generation deals
  • Brand and product management including intellectual property