News & Analysis as of

U.S. Treasury Health and Welfare Plans

McDermott Will & Emery

Landmark Mental Health Parity Final Rule: What Plan Sponsors and Insurers Need to Know

McDermott Will & Emery on

The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated final regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The newly issued...more

Verrill

Prepare for Cooler Weather, Annual Enrollment, and 2025

Verrill on

Summer is ending and fall is rapidly approaching. For employee benefit professionals with calendar-year health and welfare benefit plans that means preparing for annual enrollment and year-end compliance requirements. This...more

McDermott Will & Emery

Anticipating the MHPAEA Final Regulations: A Word About Network Composition

If our trade and industry sources have it right, we could see final regulations implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), as most recently amended by the Consolidated Appropriations Act, 2021...more

Seyfarth Shaw LLP

Agencies Defer Final Action on Junk Insurance, While Suggesting Caution Against One Last “Binge”

Seyfarth Shaw LLP on

The agencies have finalized a portion of their proposed rules impacting so-called “junk insurance” regarding short-term limited-duration insurance, but deferred finalizing the more significant changes that would have impacted...more

McDermott Will & Emery

The MHPAEA Proposed Rule: ‘Meaningful Benefits’ and the ‘Scope of Services’

McDermott Will & Emery on

This post continues our consideration of comments submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). Our previous MHPAEA content is available...more

Proskauer - Employee Benefits & Executive...

Transparency in Coverage Rules: When Accurate Estimates for Low‑Utilization Items and Services Are Not Available

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

McDermott Will & Emery

The MHPAEA Proposed Rule: Standards of Care and Medical Necessity

Comments submitted in response to the proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) reflect a broad range of perspectives. Our previous MHPAEA content is available here....more

McDermott Will & Emery

The MHPAEA Proposed Rule: Scalability and the Plight of the Small(er) Self-Funded Plan

After a brief hiatus to discuss the pleading standards adopted by the US Court of Appeals for the Tenth Circuit in E.W. v. Health Net Life Insurance Company, we return to our examination of the comments submitted in response...more

McDermott Will & Emery

The Proposed MHPAEA Regulations: Comments on Behavioral Health Carve-Out Vendors

McDermott Will & Emery on

This post continues our focus on comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The proposed regulations were issued earlier this year by the US...more

McDermott Will & Emery

The Proposed MHPAEA Regulations: A Comment on the Comments

McDermott Will & Emery on

In our last post, we considered some of the comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and...more

McDermott Will & Emery

The Proposed MHPAEA Regulations’ ‘Meaning of Terms’ Part Two: Processes, Strategies, Evidentiary Standards and Other Factors

McDermott Will & Emery on

This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the...more

McDermott Will & Emery

The Proposed MHPAEA Regulations’ ‘Meaning of Terms’ Part One: Benefits

McDermott Will & Emery on

This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the...more

McDermott Will & Emery

The ‘No More Restrictive’ Requirement for NQTLs Under the Proposed MHPAEA Regulations

McDermott Will & Emery on

We previously reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). If adopted in final form, these regulations would vastly complicate compliance by group health plans and health...more

Verrill

DOL Continues Enforcement of Non-Quantitative Treatment Limitation Requirements

Verrill on

Fifteen months ago, we wrote that the U.S. Department of Labor (“DOL”) had informed Congress that it intended to devote substantial resources to enforcing the new comparative analysis requirement for non-quantitative...more

McDermott Will & Emery

Short-Term, Limited Duration Insurance: How Long is Too Long?

McDermott Will & Emery on

On July 7, 2023, the US Departments of Health and Human Services, Labor, and Treasury (collectively, the departments) released a Notice of Proposed Rulemaking (NPRM) and Fact Sheet that proposes to revise the definition of...more

Husch Blackwell LLP

The End of the COVID Emergency and Its Impact on Group Health Plan Coverage Requirements

Husch Blackwell LLP on

After nearly three years of emergency measures related to COVID-19, the U.S. government acted this spring to officially end the COVID-19 Public Health Emergency and the National Emergency. Accordingly, the Departments of...more

Jenner & Block

Client Alert: The End of the COVID-19 Emergencies: New Joint Agency FAQs Published

Jenner & Block on

On March 29, 2023, the US Department of Labor, the Department of Health and Human Services and the Department of the Treasury (the “Joint Agencies”) released welcome guidance on the announced end of the COVID-19 national...more

Faegre Drinker Biddle & Reath LLP

COVID-19 National Emergency Plan Deadline Extensions Set to End This Summer

On January 30, 2023, President Biden announced the Administration’s plan to extend the current declarations of the COVID-19 national emergency and public health emergency (PHE) through May 11, 2023, and end both emergencies...more

Verrill

A Last-Minute Gift – Prescription Drug Reporting Grace Period and Good Faith Relief

Verrill on

In a move akin to last-minute gift-giving, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) released FAQ 56 on December 23, 2022, which provides relief regarding the Prescription Drug...more

Faegre Drinker Biddle & Reath LLP

Federal District Court Invalidates Some Surprise Billing Rules: What It Means for the No Surprises Act

On February 23, 2022, the United States District Court for the Eastern District of Texas invalidated portions of Part II of the interim final rule (“IFR”) issued by the U.S. Departments of Health and Human Services, Labor,...more

Holland & Hart - The Benefits Dial

What Happens in a Small Town Stays in a Small Town … Until the DOL Doubles Down on Mental Health Parity Compliance

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued their joint report to Congress regarding their Mental Health...more

Proskauer - Employee Benefits & Executive...

COBRA Election and Payment Periods: Does One Year of “Tolling” Really Mean One Year?

Remember the DOL/Treasury relief that tolled the COBRA election and payment deadlines for up to one year due to the COVID-19 pandemic (referred to below as “Tolling Relief”)? If you have been wondering whether, under that...more

Faegre Drinker Biddle & Reath LLP

COVID-related Benefit Plan Timeframe Extension Relief Continues With One Year Case-by-case Limit

As described in a prior blog post, last spring the Department of Labor and the Department of the Treasury (Agencies) issued COVID-19 pandemic relief that extended numerous deadlines under ERISA and the Internal Revenue Code...more

Fisher Phillips

New Benefit Plan Deadline Extensions Provide Opportunities For Participants – And Burdens For Plan Sponsors

Fisher Phillips on

The Department of Labor (DOL), in coordination with the IRS and the Treasury Department, recently issued new rules extending key deadlines for health, retirement, and welfare plans subject to ERISA and the Internal Revenue...more

Epstein Becker & Green

DOL Gives Extra Time to Plan Participants and Beneficiaries: Benefits Guidance in the Time of COVID-19

Epstein Becker & Green on

Plan participants and their beneficiaries may now have extra time to exercise some of their rights under the employee benefit plans in which they participate. ...more

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