This is the ninety-first issue in our series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of certain aspects...more
This is the 48th in a series of WorkCite articles concerning the Patient Protection and Affordable Care Act and its companion statute, the Health Care and Education Reconciliation Act of 2010 (referred to collectively as the...more
Under proposed rules recently issued by the Departments of Treasury, Labor, and HHS, employers may participate in a pilot program where they offer certain wraparound coverage as an “excepted benefit” to part-time employees,...more
On December 19, 2014, various federal agencies issued proposed regulations (“Proposed Regulations”) to amend the definition of “excepted benefits” to include certain limited wraparound health insurance coverage. “Excepted...more
A client recently asked for advice about insuring their development project with a wrap insurance policy. As we talked through the pros and cons, I was reminded of the intricacies of wrap insurance products. Undoubtedly,...more
A handful of recent guidance items that the Departments of Labor, Health and Human Services, and Treasury have issued make some important changes related to the regulation of “excepted benefits.” These changes are driven in...more
Recently issued proposed regulations would expand the categories of excepted benefits under the Employee Retirement Income Security Act of 1974 (ERISA), the Internal Revenue Code (the Code) and the Public Health Service Act. ...more
On December 24, 2013, the Departments of Treasury, Labor, and Health and Human Services (collectively, the “Departments”) jointly issued proposed rules that would expand the scope of arrangements that would constitute...more
On December 20, 2013, the Departments of Treasury, Labor, and Health and Human Services (collectively, the Departments) jointly issued proposed rules (Proposed Regulations) that would amend the regulations regarding excepted...more