Congratulations! Your money service business (MSB) has gone through the grueling process of building out all business functions, writing and implementing policies and procedures, and acquiring licenses for your covered...more
As employers look back at 2023 and ahead to 2024, there are so many compliance-related items to consider relating to their employee benefit plans. The rules employers are supposed to be complying with keep growing and...more
As part of the No Surprises progeny of legislation seeking transparency in health care, the Consolidated Appropriations Act of 2021 prohibits the use of "gag clauses" in group health plan agreements. All group health plans...more
Last week the Centers for Medicare & Medicaid Services (CMS) reminded health plans and health insurance issuers that the deadline for electronically filing attestations of compliance with the prohibition against so-called gag...more
This is a reminder that a new compliance deadline is on the horizon for group health plans. The Consolidated Appropriations Act (CAA) of 2021 generally prohibits group health plans and health insurance issuers from entering...more
By December 31, 2023, group health plans and health insurance issuers must submit an attestation to certify compliance with the “gag clause prohibition” under the Consolidated Appropriations Act of 2021 (CAA)....more
The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more
If you work for or represent group health plans or issuers of group health plans, it is important that you take a look at the contracts they have with health care providers before the end of 2023. The Internal Revenue Code...more
If you sponsor a group health plan, make sure you set a calendar alert before the winter holidays to submit the annual gag clause prohibition compliance attestation. Under the Consolidated Appropriations Act of 2021 (CAA),...more
The Florida Office of Insurance Regulation has issued an important memorandum to the insurance industry about the new Florida law that requires each authorized residential property insurer to submit, annually, an attestation...more
By December 31, 2023, health plans and insurers must submit an attestation of compliance with the “anti-gag rules” of the Consolidated Appropriations Act of 2021 (CAA). The rules apply to all agreements entered into on or...more
Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more
Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more
On June 9, 2023, the Office of Management and Budget (OMB) issued a guidance memorandum, OMB M-23-16, that extends the timeline for agencies to begin collecting attestations for critical and non-critical software from...more
Under the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers are required to annually attest that they are in compliance with the CAA’s gag clause prohibition. On a high level, the...more
The National Collegiate Athletic Association (NCAA) added numerous policy implementation resources to help institutions comply with their policy on campus sexual violence. Since 2018, each member school has been required to...more
This week, the U.S. Department of Health and Human Services (HHS) issued three additional rounds of updates to its Frequently Asked Questions (FAQs) regarding distributions from the Provider Relief Fund. The updates were...more
The U.S. Department of Health and Human Services (HHS) released portions of the $100 billion Public Health and Social Services Emergency Fund authorized by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). ...more
The CARES Act, which was signed into law on March 27, earmarks $100 billion for “health care related expenses or lost revenues that are attributable” to the COVID-19 pandemic. Legislatively titled the “Public Health and...more
On May 20, 2020, HHS issued a press release “reminding” eligible providers that they have until June 3, 2020, to accept the Terms and Conditions and submit their revenue information to support receiving additional payments...more
With just days left until provider attestations are due related to acceptance of CARES Act Provider Relief Funds, the US Department of Health and Human Services (HHS) recently updated its FAQs providing some additional...more
In response to the COVID-19 pandemic, the U.S. Department of Health and Human Services (HHS) released portions of the $100 billion Public Health and Social Services Emergency Fund authorized under the Coronavirus Aid, Relief,...more
Current SEC reporting requirements establish three different filer statuses that categorizes issuers subject to Exchange Act reporting requirements as non-accelerated, accelerated, and large accelerated filers....more
The Securities and Exchange Commission proposed amendments to the accelerated filer and large accelerated filer definitions, which have been highly anticipated. ...more
On June 28, 2018, the Securities and Exchange Commission issued a release amending the definition of “smaller reporting company” (“SRC”) to expand the number of reporting companies eligible for relaxed or scaled disclosure....more