News & Analysis as of

Health Insurance Disclosure Requirements

Bass, Berry & Sims PLC

New Reproductive Health Care Privacy Final Rule: Key Compliance Steps and Dates

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In the wake of the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization and subsequent state abortion bans, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services issued a...more

Genova Burns LLC

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

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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

Bricker Graydon LLP

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

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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

McDermott Will & Emery

Takeaways from a Recent COBRA Notice Class Action Settlement

Recent years have seen a barrage of class action lawsuits alleging that group health plan continuation coverage election notices, required under the Consolidated Omnibus Budget Reconciliation Act (COBRA), are deficient in one...more

Dorsey & Whitney LLP

Courts Address Participant Standing to Challenge Fees and Payments Received by Group Health Plan Service Providers

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As we recently suggested, ERISA disputes over the fees and expenses charged to employer or union sponsored group health plans may well become the next wave in ERISA litigation. At minimum, the Consolidated Appropriations Act...more

Polsinelli

Are You Ready? Starting August 1st, New York Imposes New Review Process for Material Transactions Involving Health Care Entities

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On May 3, 2023, New York Governor Kathy Hochul signed into law Article 45-A, amending the New York Public Health Law (“Article 45-A”). Under this new Article 45-A, health care entities in New York State are now required to...more

Goodwin

Starting in April 2024, California Joins Growing Trend of Implementing Advance Review Processes for Healthcare Transactions

Goodwin on

With the passage of SB-184 (the “Bill”), California — like Maine, New York, and several other states — has addressed “pervasive” mergers and acquisitions across the healthcare industry by requiring prior notice to regulators...more

Lippes Mathias LLP

New Disclosure and Notice Requirements for New York Physician Practice Transactions

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The 2023-2024 New York State budget has enacted significant new mandatory disclosure and notice laws for certain transactions involving physician practices and other health care organizations. This new law – Article 45-A of...more

Rivkin Radler LLP

NY Enacts Scaled-Back Version of Hochul’s Health Care Transactions Proposal

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Following extended New York State budget negotiations, lawmakers have enacted a significantly modified version of Governor Hochul’s proposed health care transaction review bill. The bill, as originally proposed, included a...more

Dechert LLP

Key Developments for Employers in the UK - Issue 4

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Welcome to the fourth edition of The Employment Edit – a summary of the most important recent cases and news affecting employers in the UK. We hope you find this newsletter helpful and informative. In this edition we look at:...more

Mitchell, Williams, Selig, Gates & Woodyard,...

National Association of Insurance Commissioners (NAIC) 2022 Summer Meeting Summary

The Mitchell Williams Insurance Regulatory team of lawyers recently attended the National Association of Insurance Commissioners (NAIC) 2022 Summer National Meeting which was held in Portland, Oregon on August 9-13th. We have...more

Foley & Lardner LLP

Postponement in the Massachusetts Patients First Act Penalties

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On July 5, 2022, the Commonwealth of Massachusetts re-extended the implementation and enforcement date for the “Patients First Act”, sometimes referred to as the Massachusetts No Surprises Act, to January 1, 2025. As...more

FordHarrison

Transparency in Coverage Requirements – Compliance Deadline Approaching

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Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022....more

Williams Mullen

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

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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

Fisher Phillips

July 1 Deadline Looming for Health Plan Transparency Rules

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In late 2020, the Departments of Health and Human Services, Labor, and Treasury (the Departments) released Transparency in Coverage (TiC) rules that put several new compliance burdens on group health plan sponsors. The next...more

Jackson Lewis P.C.

Transparency in Coverage Enforcement

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On April 19, 2022, the Departments of Labor, Health and Human Services, and the Treasury issued additional guidance under the Transparency in Coverage Final Rules issued in 2020. The guidance, FAQs About Affordable Care Act...more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Snell & Wilmer

An Interesting Intersection: No Surprises Act Claims and the New Fee Disclosure Requirements for Group Health Plans

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As reported in our January 7, 2022 SW Benefits Blog “The DOL Asks and Answers Questions About the New Welfare Plan Fee Disclosure Rules,” group health plans must now comply with the ERISA Section 408(b)(2) disclosure...more

Groom Law Group, Chartered

Illinois Employers: Are You Complying With the Consumer Coverage Disclosure Act?

Illinois recently enacted the Consumer Coverage Disclosure Act (the “CCDA”), which requires that Illinois employers provide a disclosure to employees regarding how the employer’s group health plan compares with the essential...more

Ballard Spahr LLP

Understanding the New Health Care Transparency Requirements

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Summary - New rules require group health plans and insurers to disclose pricing information in three phases. This is the third briefing in Ballard Spahr’s series on the Consolidated Appropriations Act, 2021 (CAA) and...more

Proskauer - Employee Benefits & Executive...

DOL Announces Temporary Enforcement Policy and Guidance to Address New Compensation Disclosure Requirements for Service Providers...

On December 30, 2021, the U.S. Department of Labor (“DOL”) issued Field Assistance Bulletin No. 2021-03 (“FAB”), announcing its temporary enforcement policy for group health plan service provider disclosures under ERISA...more

Seyfarth Shaw LLP

Guidance Arrives on Long-Awaited Compensation Disclosures for Group Health Plans

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Seyfarth Synopsis: Almost a decade after the 408(b)(2) fee disclosure requirements took effect for retirement plan service providers, Congress finally passed legislation addressing compensation disclosure rules for service...more

Epstein Becker & Green

Video: Getting Ready for the No Surprises Act - Thought Leaders in Health Law

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Is your organization ready for the No Surprises Act (NSA)? The law goes into effect January 1, 2022, and contains a new federal ban on surprise billing as well as new disclosure requirements. The NSA applies to certain...more

Foley & Lardner LLP

The Consolidated Appropriations Act’s Compensation Disclosure Provisions from a Carrier and Plan Service Provider Perspective

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...The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) sets forth new compensation disclosure requirements that apply to brokers and consultants with respect to both fully-insured and self-insured group health...more

Carlton Fields

FOIR Releases Guidance on New Disclosure Requirements for Health Insurers, MCOs

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The Florida Office of Insurance Regulation released an informational memorandum on Friday to all health insurers and managed care organizations authorized to do business in Florida to provide guidance regarding new disclosure...more

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