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

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

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Mental Health Parody: In A Cruel Prank, Agencies Respond to Employer Pleas for Guidance with More Stringent Regulations

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”

Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more

OMG! OMB Reviewing Long-Awaited Mental Health Parity Regulations – Public Release Imminent

Seyfarth Synopsis: Employer health plan sponsors, administrators, and insurers have been eagerly awaiting the U.S. Department of Labor’s upcoming guidance on mental health parity.  According to recent reports, newly proposed...more

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

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

IRS Releases Extensive Guidance on ARPA COBRA Subsidy

Seyfarth Synopsis: On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”), which requires plan sponsors to provide free COBRA coverage from April 1, 2021 through September 30, 2021, to...more

ARPA COBRA Subsidy: DOL Releases Model Notices, Punts (to IRS?) on Most Open Issues

Seyfarth Synopsis: As discussed in our March 11, 2021 Alert, Congress has made another avenue of health coverage more accessible by fully subsidizing the cost of COBRA coverage from April 1 - September 30, 2021 for...more

DOL Addresses Health Plan Coverage for Return-to-Work COVID Testing and Other Pressing Issues

Seyfarth Synopsis: On June 23, 2020, the DOL issued additional FAQs relating to the COVID-19 testing mandate under the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief and Economic Security Act...more

How COBRA Got Her Groove Back: Old Law Gets New Focus From DOL, Class Action Plaintiffs’ Attorneys

Synopsis: After falling out of favor post-Affordable Care Act, when Health Insurance Marketplace coverage became a far more attractive post-termination health coverage alternative, everyone is once again talking about COBRA...more

Months After Ordering Plans to Disregard Sub-Regulatory Guidance, Trump Administration Learns to Love the Informal FAQs

Seyfarth Synopsis: On April 11, the IRS, DOL and HHS issued a series of FAQs clarifying the scope of the FFCRA/CARES Act mandates relating to COVID-19 testing for group health plans and health insurance issuers. This post...more

Issue 91: Agencies Issue Guidance on Wraparound Coverage and Supplemental Insurance Products as Excepted Benefits

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

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