News & Analysis as of

U.S. Treasury Health Insurance Portability and Accountability Act (HIPAA)

Verrill

Prepare for Cooler Weather, Annual Enrollment, and 2025

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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

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2023 # 4

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To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more

Dentons

It’s Time to Give Your Patient Finance Program a Check-Up

Dentons on

On July 7, 2023, the Consumer Financial Protection Bureau, U.S. Department of Human Services, and U.S. Department of Treasury (collectively, the “agencies”) launched an inquiry into high-cost specialty financial products...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 10, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Snell & Wilmer

Five Facts About the Annual Gag Clause Prohibition Compliance Attestation

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Effective December 27, 2020, the Consolidated Appropriations Act, 2021 (“CAA”), as part of its transparency in health care protections, prohibits group health plans and issuers from entering into agreements that directly or...more

Husch Blackwell LLP

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

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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

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers

The Biden administration has announced its intention 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)....more

Laner Muchin, Ltd.

Employers Face Another Annual Disclosure for their Group Health Plan Related to the No Surprises Act: “Gag Clauses”

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The No Surprises Act (the NSA) bans “gag clauses” that prevent disclosure of price or quality information in agreements between health plans and certain service providers. In addition, the NSA requires plan sponsors to attest...more

Sherman & Howard L.L.C.

The End of the Line Draws Near for COVID-19 Plan Deadline Extensions

On January 30, 2023, the Biden Administration released a Statement of Administration Policy providing that the Administration intends to end the COVID-19 National Emergency declared in 2020 (the “National Emergency”) on May...more

McDermott Will & Emery

Agencies Clarify How Employers Can Charge COVID-19 Vaccine Premium Incentives

McDermott Will & Emery on

On October 4, 2021, the US Departments of Labor, Treasury, and Health and Human Services (the Tri-Agencies) issued guidance regarding the application of the Health Insurance Portability and Accountability Act (HIPAA) wellness...more

Laner Muchin, Ltd.

Federal Regulators Clarify the Application of HIPAA Privacy and Nondiscrimination Rules to COVID-19 Vaccines in the Workplace

Laner Muchin, Ltd. on

On September 30, 2021, the Department of Health and Human Services (HHS) issued FAQs addressing how the HIPAA Privacy Rule applies to individuals’ disclosures of their COVID-19 vaccination status in the workplace and health...more

Parker Poe Adams & Bernstein LLP

Federal Agencies Issue FAQ on Health Plan Premium Discounts for COVID-19 Vaccinations

The federal Centers for Medicare & Medicaid Services (CMS) issued a set of Frequently Asked Questions about the interaction of HIPAA, the Affordable Care Act, and various group health plan issues relating to the COVID-19...more

Mintz - Employment Viewpoints

Departments of Labor, Health and Human Services, and the Treasury Clarify Rules Governing Premium Surcharges/Discounts Related to...

The Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) recently issued a set of Frequently Asked Questions—FAQs About Affordable Act Implementation, Part 50, Health Insurance Portability and...more

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

COVID-19 Vaccine Incentives Without the HIPAA Headache

On February 26, 2021, the U.S. Department of Labor, along with the U.S. Department of Health and Human Services and the U.S. Department of the Treasury, issued answers to new frequently asked questions (FAQs) interpreting...more

Husch Blackwell LLP

New Developments: Clarification On Extensions Of Benefit Deadlines

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On February 26, 2021, the Department of Labor, the Treasury Department and Internal Revenue Service issued clarifying guidance regarding COVID-19-related deadline extensions under the Internal Revenue Code, ERISA, COBRA and...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - March 2021 #3

Troutman Pepper on

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Holland & Hart - Employers' Lawyers

EEOC’s New Stand on Wellness Programs

On January 7, 2021, the Equal Employment Opportunity Commission unveiled two Notices of Proposed Rulemaking regarding what employers can do to encourage workers to participate in corporate wellness programs without violating...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter-September 2020 #2

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Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Troutman Pepper

D.C. Circuit Upholds Short Term Plans as Alternative to ACA Plans

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On July 17, 2020, a panel majority of the D.C. Circuit Court of Appeals upheld a rule issued by the Department of Treasury, the Department of Labor, and the Department of Health and Human Services (collectively, the...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

Groom Law Group, Chartered

DOL & Treasury Extend ERISA-Required Deadlines, Creating Questions & Disruptions in Administrative Procedures

On April 29, 2020, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) issued guidance extending certain deadlines related to retirement, health, and welfare plans in response to the current COVID-19...more

Stoel Rives LLP

Important Deadlines Delayed for Health and Welfare Plans due to COVID-19 Emergency; Updated Model COBRA Notices Issued

Stoel Rives LLP on

The Employee Benefits Security Administration (EBSA) of the Department of Labor (DOL) and the Department of Treasury and Internal Revenue Service (IRS) issued a notification of relief, effective immediately, that extends...more

McDermott Will & Emery

Spotlight on Sensitive Personal Data as Foreign Investment Rules Take Force

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New CFIUS rules—which took effect February 13, 2020—underscore the need for privacy diligence in deals involving foreign investments and signal a larger trend toward heightened regulatory scrutiny of foreign access to...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations Part 4: Excepted Benefit HRAs

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) have expanded the use of health reimbursement arrangements (“HRAs”), including permitting the use of HRAs to...more

Burr & Forman

What the HRA is going on with HRAs?

Burr & Forman on

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

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