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
In reaction to growing concerns about testing for and treatment of COVID-19, clients with high-deductible group health plans (and related health savings accounts) have been asking whether plans can provide testing and...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