Final Rules

News & Analysis as of

Government Agencies Release Further Accommodations to Organizations Opposing Mandated Contraceptive Coverage

In response to the recent U.S. Supreme Court decision in Burwell v. Hobby Lobby, Inc., the U.S. Departments of Health and Human Services (HHS) and Labor (DOL) published proposed rules on August 22, 2014, expanding the...more

PBGC Publishes Final Regulations on the Phase-In Period for Guarantee of Benefits for an Unpredictable Contingent Event

The Pension Benefit Guarantee Corporation (“PBGC”) recently published final regulations related to the phase-in period for its guarantee of benefits that are contingent upon the occurrence of an “unpredictable contingent...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 18: Emerging Strategies to Reduce or Eliminate Exposure for...

The Affordable Care Act’s employer shared responsibility, or “pay-or-play,” rules require “applicable large employers” (generally employers with 50 or more full-time and full-time equivalent employees) to offer group health...more

EPA Publishes Final 316(b) Rule: Flexibility for Generators Means Litigation By Environmental Groups

Last Friday, EPA finally published its § 316(b) rule in the Federal Register. As we noted in May, the rule is more significant for what it does not do – require closed cycle cooling – than for what it does....more

Don’t forget the September 23, 2014 deadline to ensure your Business Associate Agreements comply with the Omnibus Final Rule

Under the Health Insurance Portability and Accountability Act (HIPAA) Omnibus Final Rule published January 25, 2013, 78 Fed.Reg. 5566, Covered Entities (CEs) with Business Associate Agreements (BAAs) that were entered on or...more

CFPB publishes annual CARD Act, HOEPA and QM adjustments

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

CMS Publishes FY 2015 Final IPPS Rule

On August 4, 2014, CMS posted its final changes and updates to the Medicare Inpatient Prospective Payment System (IPPS) that apply for fiscal year (FY) 2015, effective October 1, 2014. Below are some of the highlights of the...more

EPA Extends 2013 RFS Compliance Deadline, Again

On July 31, 2014, EPA again extended the 2013 Renewable Fuel Standard (RFS) annual compliance reporting and attest engagement reporting deadlines for obligated parties under the law. The Agency issued a direct final rule...more

IRS Finally Releases Clarifications to PTC “Start of Construction” Guidance

On Friday, the Internal Revenue Service (IRS) issued Notice 2014-46, which clarifies the rules for a wind project to be deemed to have started construction in 2013 as is necessary to be eligible for production tax credits...more

RFS Update: EPA Indefinitely Extends 2013 RFS Compliance Deadlines, Final 2014 RFS Still Awaited

As reported in a previous blog, EPA in June extended the compliance and attest engagement reporting deadlines for the 2013 Renewable Fuel Standard (RFS) to September 30, 2014 and January 30, 2015 (respectively). Today, EPA...more

Health Headlines: Also in the News - August 2014

Hospital IPPS Final Rule Not Yet Released – As of the time this edition of Health Headlines was sent to press, CMS has not yet released the hospital inpatient prospective payment system (IPPS) final rule for FY 2015....more

SEC Adopts Reforms for Money Market Funds

On July 23, 2014, the Securities and Exchange Commission (the “SEC”) voted three-to-two to adopt significant new reforms for money market funds (“MMFs”) (the “Final Rule”). The reforms are intended to reduce the...more

New ICD-10 Compliance Date Set for October 1, 2015

On July 31, 2014, CMS issued a final rule moving the ICD-10 compliance date from October 1, 2014 to October 1, 2015, and requiring HIPAA covered entities to continue to use ICD-9 through September 30, 2015. The final rule...more

IRS Issues Final Regulations On Longevity Annuities

With the goal of providing retirees with more options to manage their retirement income, the IRS issued final regulations on “qualified longevity annuity contracts” (QLACs). A QLAC is a type of deferred annuity that commences...more

Form PF Amendments Expand Disclosure Requirements for Large Liquidity Fund Advisers: Are You Prepared?

On July 23, 2014, the Securities and Exchange Commission (“SEC”) adopted final rules governing money market funds in a release adopting amendment to Rule 2a-7 under the Investment Company Act of 1940 and other related...more

Summary of New Money Market Fund Rules Adopted by the SEC

On July 23, 2014, the Securities and Exchange Commission (the SEC) adopted final rules governing the structure and operation of money market funds, in a release adopting amendments to Rule 2a-7 under the Investment Company...more

The LCIA’s New 2014 Arbitration Rules

The London Court of International Arbitration (“LCIA”) has published in final form its new arbitration rules (the “2014 Rules”), which will apply to arbitrations commenced after 1 October 2014. ...more

Update: Final Rules Clarify New York City Employers’ Sick Leave Obligations

In response to widespread employer concerns over ambiguities in New York City’s Earned Sick Time Act (“ESTA”), the New York City Department of Consumer Affairs (“DCA”) published its Final Rules regarding the ESTA on July 30,...more

Health Care Reform Implementation Update

Congress begins its summer recess this week, but last week legislators were busy holding hearings on management issues regarding HealthCare.gov, introducing legislation to increase payments to primary care doctors under...more

Most Recent Final Deadline for ICD-10 Implementation is October 1

It’s been a while since CMS set a new “final” deadline for implementation of ICD-10—the greatly expanded medical coding system. So last Thursday CMS issued a new final rule setting October 1, 2015, as the final date for...more

New Tax Guidance Would Simplify Rules for Shareholders of Institutional Money Market Funds

On July 23, 2014, the Securities and Exchange Commission (SEC) adopted final rules governing the structure and operation of money market funds (SEC MMF Reform Rules). See our client alert entitled “SEC Adopts Floating-NAV and...more

Energy And Commerce Chair Working On RFS Reform

Reportedly, U.S. House Energy and Commerce Committee Chair Fred Upton (R-MI) plans to introduce a bill to modify the federal Renewable Fuel Standard (RFS). The bill is expected to be introduced soon after EPA releases its...more

The Probe and Educate Process For The Two-Midnight Rule

On August 2, 2013, the Centers for Medicare and Medicaid Services (“CMS”) released the final rule for the 2014 Medicare Inpatient Prospective Payment System (“IPPS”), effective October 1, 2013.[1] Introduced in the IPPS...more

Mitigating Longevity Risk in DC Plans

401(k) participants face the risk of outliving retirement assets. However, earlier this month, the Internal Revenue Service and the Treasury Department issued final regulations that make it easier for 401(k) plans, individual...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 23: The Impact of Employment Contract Terms on Variable Hour...

For applicable large employers (i.e., employers who employed at least 50 full-time and full-time equivalent employees on business days during the preceding calendar year) endeavoring to comply with the Affordable Care Act’s...more

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