News & Analysis as of

Employer Group Health Plans Consolidated Appropriations Act (CAA)

Epstein Becker & Green

Mental Health Parity: Federal Departments of Labor, Treasury, and Health Release Landmark Regulations

Epstein Becker & Green on

On September 9, 2024, the three federal departments responsible for regulating the health care benefits for more than 175 million Americans with private health insurance issued a final rule (the “Final Rule”) implementing...more

Epstein Becker & Green

Three Things That Employer Health Plan Sponsors Should Do When the New MHPAEA Rules Are Published

Epstein Becker & Green on

The U.S. Departments of Labor (DOL), Health and Human Services, and the Treasury (collectively, the “Tri-Departments”) published a Notice of Proposed Rulemaking (NPRM) on August 3, 2023, to propose new regulations for the...more

Jackson Lewis P.C.

Health Plan Hygiene Part 1: A Spoonful of Sugar Helps the Medicine Go Down

Jackson Lewis P.C. on

During the next several weeks, we will publish a series of articles that dive deeply into “health plan hygiene” relating to health and welfare benefit plan fiduciary issues and how employers can protect themselves in this...more

Verrill

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

Verrill on

Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

Woodruff Sawyer

Compliance Alert: Reminder: RxDC Reporting Due June 1st

Woodruff Sawyer on

As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to...more

Holland & Hart - The Benefits Dial

Go Your Own Way (Or Maybe Not): New Heightened Fiduciary Standards are Coming to Group Health Plans

There has been a shift taking place in ERISA litigation and compliance that could significantly impact group health plan fiduciary requirements. We anticipate group health plan fiduciary standards will evolve along the same...more

McGuireWoods LLP

A New Frontier for ERISA Fee Suits: Group Health Plans

McGuireWoods LLP on

Best practices in the area of ERISA health and welfare plan governance are evolving. Concerned group health plan fiduciaries have been evaluating compliance processes while facing a set of rigorous fiduciary duties imposed by...more

Littler

Sponsoring a Group Health Plan for Employees? What Employers Need to Know About the Consolidated Appropriations Act

Littler on

Many employers offer health insurance as a way to recruit and retain talent. Sponsoring a group health plan, however, can subject the employer plan sponsor to significant legal and regulatory burdens deriving from laws such...more

Baker Donelson

Surprise! Gag Clause Attestation Due by 12/31/2023

Baker Donelson on

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

Alston & Bird

Year-End Health Benefits Roundup 2023

Alston & Bird on

It was a lively year for health benefits. Our Employee Benefits & Executive Compensation Group unpacks 2023, from the end of the COVID-19 emergencies to the much-anticipated Mental Health Parity and Addiction Equity Act...more

Holland & Hart - The Benefits Dial

Signed, Sealed, Delivered … Have You Completed Your Plan’s “No Gag Clauses” Attestation?

One of the many benefits-related provisions in the Consolidated Appropriations Act of 2021 prohibits the use of “gag clauses” in group health plan agreements. Before this law, medical plan service agreements would often...more

Manatt, Phelps & Phillips, LLP

The Gag Clause Prohibition Compliance Deadline Is Approaching: What Plans and Issuers Need to Know

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

Genova Burns LLC

Heads Up To Group Health Plans: December 31 Gag Clause Attestation Deadline Approaches

Genova Burns LLC on

The Consolidated Appropriations Act of 2021 prohibits group health plans from agreeing to avoid making certain disclosures of provider-specific cost or quality-of-care information. This is referred to as the gag clause...more

Jenner & Block

Client Alert: Group Health Plan “Gag Clause” Compliance Attestation Due by the End of 2023

Jenner & Block on

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

Bass, Berry & Sims PLC

Let the Plan Speak: First Gag Clause Attestation Due December 31, 2023

Bass, Berry & Sims PLC on

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

Faegre Drinker Biddle & Reath LLP

Reminder: Gag Clause Attestations Due by Year-End

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

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

Morgan Lewis - ML Benefits

First Gag Clause Attestations Due From Group Health Plans by December 31

The Consolidated Appropriations Act, 2021 (CAA), requires group health plans and insurers to annually attest that they are in compliance with the gag clause prohibition under the CAA. The first attestation is due no later...more

Foley & Lardner LLP

Action Steps Health Plans Should Take Now In Response To New DOL Guidance on Mental Health Parity

Foley & Lardner LLP on

The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...more

Bond Schoeneck & King PLLC

Don’t Choke on the Gag Clause Prohibition Compliance Attestation Requirement of the CAA

On or before Dec. 31, 2023, certain group health plans and health insurance issuers must submit an attestation to the U.S. Department of Health and Human Services (HHS) certifying their compliance with the “gag clause...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Proposed Rules Push Mental Health Parity Up Benefit Priority List

Now you know. It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Mental Health Parity Compliance Remains a Key Focus for Federal Agencies

On July 25, 2023, the U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of the Treasury released their annual report to the U.S. Congress regarding group health...more

Manatt, Phelps & Phillips, LLP

First Look at Proposed New Federal Mental Health Parity Rules

Last week, the departments of the Treasury, Labor and Health and Human Services (collectively, the Departments) published long-awaited proposed regulations intended to clarify and improve compliance with the federal mental...more

Warner Norcross + Judd

Preparing for Health Plan Anti-Gag Clause Attestation

Although the end of the year seems far away, employers should start preparing for the anti-gag clause attestations for their group health plans that are due December 31. Namely, employers need to determine who is completing...more

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