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Five Facts About the Annual Gag Clause Prohibition Compliance Attestation

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

In Case You Missed It – Summer 2021

Summer has come and gone, but there was no summer vacation for employee benefits legislation and guidance. In case you have been too busy to check out our blogs lately, here are some key items to help you stay organized and...more

Not All Surprises Are Good – Phase I of the Surprise Billing Rules

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (collectively the “Departments”) issued the interim final rule...more

Must Drug Manufacturer Coupons Count Toward Annual Maximum Out-Of-Pocket Limits? Stay Tuned …

What is the Annual Maximum Out-Of-Pocket Limit (“MOOP”)? MOOP is the most a participant must pay for covered services under a group health plan in a plan year. After a participant spends this amount on deductibles,...more

HHS to Start Randomly Selecting Health Plans for HIPAA Compliance – Are You Ready?

The CMS Division of National Standards, on behalf of HHS, is launching the Compliance Review Program (the “Program”) to ensure compliance among covered entities with HIPAA Administrative Simplification rules for electronic...more

2017 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare

As 2017 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we are presenting our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 will cover...more

Recent Mental Health Parity Guidance — A Good Reminder to Review Your Health Plan for Compliance

The Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”) generally requires that the financial requirements and treatment limitations that apply to mental health and substance use disorder (“MH/SUD”) benefits...more

2017 HIPAA Enforcement – Appears Not To Be Slowing Down

To state the obvious, there has been some uncertainty regarding how the Trump Administration will affect federal agency enforcement efforts. However, at least, in regard to HIPAA Privacy and Security, the U.S. Department of...more

You Received a Health Insurance Marketplace Notice from HHS – Now What?

Take a deep breath. The HHS Health Insurance Marketplace Notice (the “Notice”) may seem to be a nuisance, but it does not necessarily mean that you will be subject to employer shared responsibility penalties....more

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