Medical Device Legal News with Sam Bernstein: Episode 19
Midyear Premium Increases and Cafeteria Plan Rules
K&L Gates Triage: An Insider’s Perspective on the Health Care Debate in Washington, DC
K&L Gates Triage: 340B Regulatory Update: CMS Proposal and Draft Executive Order Could Have Big Impact on 340B Program
Collaborating Before The PTAB
Last week, the Departments of Labor, Treasury and Health and Human Services (“the Departments”) issued an FAQ about the final Transparency in Coverage rules (“TiC Rules”). This FAQ addresses compliance with cost‑sharing...more
Summary - Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision....more
Where did the time go? Just a brief 1,199 days after it began, the COVID-19 Public Health Emergency (PHE) is coming to an end. The PHE formally ends on May 11, 2023, short of any unexpected developments. And that means the...more
On March 30, 2023, the District Court for the Northern District of Texas issued an opinion and order in Braidwood Mgmt. Inc. v. Becerra that vacates the implementation and enforcement of certain preventive service provisions...more
The Consolidated Appropriations Act of 2022 (“2022 CAA”), which was recently signed into law, reinstates the exception that allows high deductible health plans (“HDHPs”) to waive all or a portion of participant cost-sharing...more
A few short weeks ago we told you in a blog post that, with only four days’ notice, the Departments of Labor, Treasury, and HHS (the Departments) required that, starting January 15, 2022, group health plans cover FDA-approved...more
On Monday, the government issued frequently asked questions (FAQs) requiring employer group health plans (Plans) and health insurance issuers to cover certain over-the-counter (OTC) COVID-19 tests at no cost to the...more
Effective January 15, 2022, health plans are required to cover the cost of over-the-counter (“OTC”) COVID-19 test kits obtained without a health care provider’s prescription or clinical assessment. This new requirement was...more
Beginning January 15, 2022, and through the duration of the public health emergency, insurers and group health plans must cover at-home COVID-19 diagnostic tests available over-the-counter (OTC) without imposing cost-sharing,...more
Looking forward to the weekend? Many employers and plan administrators may also have been . . . up until yesterday, when the government issued new requirements that take effect on Saturday. ...more
On July 13th, group health plans and health insurance issuers subject to the Federal No Surprises Act (the “Act”) received the first phase of interim final rules promulgated under the Act (the “Rules”) and issued by the...more
On July 19, 2021, the Internal Revenue Service, U.S. Department of Labor, and the U.S. Department of Health and Human Services (the “Tri-Agencies”) issued new frequently asked questions (FAQs) regarding the implementation of...more
On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more
The U.S. Departments of Health and Human Services, Labor, and Treasury, and the Office of Personnel Management have issued "Requirements Related to Surprise Billing; Part I," an interim final rule to implement the No...more
Carlton Fields tax attorney Lowell Walters discusses issues that can arise when employers with group health plans increase the premiums paid by employees midyear, which we might see more of since certain grandfathered health...more
On December 6, 2020, we posted an article titled “RADICAL new transparency rules likely apply to your health plan in one year.” The regulations are a little more than 150 PDF pages long. The following is intended to provide a...more
Following a presentation to the Association of Corporate Counsel (ACC) in Georgia, Nelson Mullins attorneys Ann Murray and Matt Zischke shared additional insights into the evolving effects of the COVID-19 pandemic on group...more
New rules published last month likely require your employer health plan to phase-in certain disclosures over a three-year period beginning in one year: 1. January 1, 2022 (three files must be disclosed): For plan years...more
Seyfarth Comments: The final Transparency in Coverage Rule was published jointly by the Departments of Health and Human Services, Treasury, and Labor on November 12, 2020. The Rule aims to increase transparency in...more
A second round of FAQs recently issued by the Labor Department, the IRS, and the Department of Health and Human Services provides plan sponsors and insurers with additional implementation guidance relating to health coverage...more
Seyfarth Synopsis: On June 23, 2020, the DOL issued additional FAQs relating to the COVID-19 testing mandate under the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief and Economic Security Act...more
The U.S. Departments of Labor, Health and Human Services, and the Treasury have jointly published a set of frequently asked questions that offer guidance on a number of benefits issues related to the expansion of coverage...more
As the harsh realities of the coronavirus pandemic, along with its widespread impact on all aspects of daily life, continue to shock and numb us all, many cities have already been identified as “high risk” from a financial...more
The nation’s lawmakers, government agencies, and insurance carriers are taking measures to remove financial barriers to testing and treatment for the novel coronavirus disease (COVID-19). Employers sponsoring health plans...more
HDHP and HSA participants - The IRS has expanded prior guidance to allow health plans to pay first-dollar costs for testing and treatment of COVID-19 without jeopardizing the participant’s HSA eligibility. ...more