Bass Berry & Sims' Health Reform Impact takes a look at the impact of two new regulations pertaining to medical loss ratio (MLR) from the U.S. Department of Health and Human Services.

Specifically the Regulations amend provisions governing mini-med and expatriate plans, revise how rebates may be issued in the group markets, and allows some implementation costs associated with the International Classification of Diseases – Tenth Revision (“ICD-10”) conversion to be counted as a clinical expense.  Perhaps most controversial is what the Regulations do not change: agent and broker compensation and fraud prevention activities continue as administrative costs for MLR calculations.