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By: Amy M. Gordon, Ann Killilea, Michael G. Morgan, Susan M. Nash, and Angela M. Stockbridge , McDermott Will & Emery LLP. The U.S. Department of Health and Human Services (HHS) recently issued guidance under the Health Insurance Portability and...

By: Zach P. Hutton and Justin M. Scott , Paul Hastings. Introduction In Flores v. City of San Gabriel , 1 the Ninth Circuit Court of Appeals considered an issue of first impression: whether “cash-inlieu of benefits” payments made directly...