The Consolidated Appropriations Act, 2021 (the CAA), which was enacted on December 27, 2020, contained a number of significant transparency and disclosure requirements for group health plans. In particular, the CAA requires...more
Earlier this year, the IRS issued final regulations implementing the employer shared responsibility provisions (the “Pay-or-Play Mandate”) of the Patient Protection and Affordable Care Act (“PPACA”). We issued a Client...more