News & Analysis as of

Health Insurance Deadlines

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

Akerman LLP - Health Law Rx

ACTION REQUIRED TO AVOID FINES! DEADLINE APPROACHING: Florida Pharmacy Benefit Managers Must Be Licensed as a Third-Party...

Pharmacy Benefit Managers (PBMs) take note! Under Florida’s new Prescription Drug Reform Act, PBMs must be licensed as an insurance administrator (also known as a third-party administrator, or TPA). Under this new law, any...more

Woods Rogers

Does the Fun Ever Stop? COVID-19 Tolling Ends for COBRA Deadlines

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On April 10, 2023, President Biden signed legislation to end the COVID-19 national emergency effective immediately, including ending the requirement to extend COBRA deadlines due to the COVID-19 pandemic. Plan administrators...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Deadline Tolling

McDermott Will & Emery on

The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April...more

McDermott Will & Emery

[Webinar] How Employers Should Prepare for the End of the Covid-19 National & Public Health Emergencies - April 3rd, 12:00 pm -...

McDermott Will & Emery on

The Biden administration recently announced its intention to end the COVID-19 National Emergency and the COVID-19 Public Health Emergency effective May 11, 2023. These emergency declarations have been in place for nearly...more

Bass, Berry & Sims PLC

Tolling No More: Preparing for the End of COVID-19 Emergency Declarations

On January 30, President Biden announced his intention to end the COVID-19 National Emergency (NE) and Public Health Emergency (PHE) effective May 11, 2023. Both emergency declarations resulted in various forms of relief for...more

Seyfarth Shaw LLP

Another Health Plan Reporting Deadline Is “In the Air”

Seyfarth Shaw LLP on

Seyfarth Synopsis: Under a Tri-Agency Proposed Rule, health plans could be required to report information relating to air ambulance services by March 31, 2023. As this proposed deadline approaches, plan sponsors should reach...more

Woodruff Sawyer

Compliance Alert: IRS Releases Final Rules Extending Deadline to Furnish ACA Reporting Forms

Woodruff Sawyer on

On December 12, 2022, the IRS released a Final Rule providing for, among other things, an automatic 30-day extension of time for applicable large employers (“ALEs”) to furnish annual Form 1095-C to individuals for calendar...more

Foley & Lardner LLP

Upcoming Deadline Under The No Surprises Act – Air Ambulance Reporting By Group Health Plans and Insurance Issuers

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Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...more

Fisher Phillips

5 Most Important Steps for Employers Doing Their 2023 ACA Compliance Planning

Fisher Phillips on

Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Health Plan Transparency Requirements

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt is joined by his colleague, Allison Carlon, who helps us better understand what employers need to know about the Consolidations Appropriations Act...more

Robinson & Cole LLP

January 1, 2022 Deadline for Plan Sponsors to Post Surprise Billing Notice

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The January 1, 2022, deadline is approaching for plan sponsors to post the required notice informing participants of certain changes affecting how medical benefits may be billed under their health plan. This notice is...more

Bradley Arant Boult Cummings LLP

IRS Proposes Regulations on ACA Reporting: Good News and Bad News for Employers

The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Fisher Phillips

September 15 Deadline Looming for Required ARPA Notices

Fisher Phillips on

The American Rescue Plan Act of 2021 (ARPA) mandates that group health plans that are subject to COBRA must provide coverage to certain assistance eligible individuals (AEI) at no cost for periods of coverage between April 1,...more

Carlton Fields

COBRA Deadlines and Proofs of Mailing in Carter v. Southwest Airlines Co. Board of Trustees

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Carlton Fields tax attorney Lowell Walters explains what we can learn about a recent case in which a former employee claimed to be owed benefits, and provides suggestions on how companies can protect themselves. The video...more

Morgan Lewis - ML Benefits

Suspended Deadlines Under ERISA: Is It Time to Restart the Clock?

As we described in our LawFlash from last spring, the US Department of Labor’s Employee Benefits Security Administration (EBSA) and the Internal Revenue Service (IRS) (collectively, the Agencies) issued EBSA Notice 2020-01...more

Ballard Spahr LLP

CMS Addresses Extended Deadlines for Benefit Plans

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The Department of Health and Human Services Centers for Medicare & Medicaid Services (CMS) has followed the guidance, jointly issued by the U.S. Departments of Labor and the Treasury, that extends benefits-related deadlines...more

Littler

COBRA is Temporarily Social Distancing From its Election and Payment Deadlines

Littler on

The IRS and DOL issued guidance on May 4, 2020 that adds a new level complexity to COBRA administration for employer-sponsored plans.  In short, the relief suspends many key participant deadlines during the so-called...more

Robinson & Cole LLP

Joint Agency Guidance Extends COBRA and Other ERISA Deadlines

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On May 4, 2020, the Department of Labor and Department of Treasury (the Departments) issued joint guidance requiring certain COBRA, HIPAA and ERISA deadlines be determined without regard to the “Outbreak Period,” which began...more

Dickinson Wright

Benefits Briefs in the Time of COVID-19, Part 1: Federal Agencies Relax Summary of Benefits and Coverage (“SBC”) Disclosure...

Dickinson Wright on

Recent guidance from the Department of Labor (“DOL”), Health and Human Services (“HHS”) and Treasury (the “Departments”) provides limited enforcement relief from the summary of benefits and coverage (“SBC”) disclosure rules...more

Neal, Gerber & Eisenberg LLP

State of New Jersey Extends Health Coverage State Reporting Deadline

In response to the repeal of the individual health coverage mandate, New Jersey passed the New Jersey Health Insurance Market Preservation Act (the "Act") which generally requires individuals who reside in New Jersey to...more

Ballard Spahr LLP

New Jersey Extends Deadline for Health Coverage Filings

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On March 19, 2020, the New Jersey Department of Treasury announced that it extended the deadline for applicable coverage providers to file Forms 1095 with the New Jersey Division of Taxation from March 31, 2020, to May 15,...more

Seyfarth Shaw LLP

Deadline is Approaching for Group Health Plan Service Agreement Updates

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Seyfarth Synopsis: Recent changes to the federal rules governing confidentiality of substance use disorder (SUD) patient records may require updates to agreements between group health plans and their third-party vendors....more

Snell & Wilmer

A Holiday Surprise – IRS Extends Certain ACA Reporting Deadlines and Transition Relief

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The IRS delivered welcome news to employers preparing to meet the Affordable Care Act’s (“ACA”) information reporting deadlines in early 2019 for the 2018 calendar year. In Notice 2018-94 (the “Notice”), the IRS extended the...more

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