The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more
1/27/2025
/ Consolidated Appropriations Act (CAA) ,
Contract Terms ,
Data Privacy ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Employee Benefits ,
Employer Group Health Plans ,
Enforcement Actions ,
Gag Clauses ,
Health Insurance ,
Office of Personnel Management (OPM) ,
Reporting Requirements ,
Third-Party Service Provider ,
U.S. Treasury
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
8/30/2024
/ Benefit Plan Sponsors ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Liability Issues ,
Fiduciary Duty ,
Final Rules ,
Health and Welfare Plans ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Medicare Part D ,
Reproductive Healthcare Issues ,
U.S. Treasury
In 2021, the Department of Health and Human Services (HHS) proposed changes to the Privacy Rule under the Health Insurance Portability and Accessibility Act of 1996 (HIPAA) that would significantly alter the current...more
11/30/2023
/ Department of Health and Human Services (HHS) ,
Health and Welfare Plans ,
Health Care Providers ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Healthcare ,
Healthcare Reform ,
HIPAA Privacy Rule ,
NPRM ,
OCR ,
Policies and Procedures ,
Popular ,
Privacy Laws ,
Proposed Rules
Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more
6/5/2023
/ Benefit Plan Sponsors ,
Centers for Medicare & Medicaid Services (CMS) ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Final Rules ,
Gag Clauses ,
Health Insurance ,
Health Plan Sponsors ,
New Guidance ,
Reporting Requirements ,
Transparency ,
U.S. Treasury
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
12/28/2022
/ Benefit Plan Sponsors ,
Consolidated Appropriations Act (CAA) ,
Data Collection ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Good Faith ,
Grace Period ,
Health and Welfare Plans ,
Insurance Industry ,
Pharmaceutical Industry ,
Prescription Drugs ,
Reporting Requirements ,
U.S. Treasury
The U.S. District Court for the Eastern District of Texas recently vacated a portion of the Requirements Related to Surprise Billing, Part II, Interim Final Rule (the “Rule”) regarding the independent dispute resolution (IDR)...more
3/1/2022
/ Appeals ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Health Care Providers ,
Health Insurance ,
Insurance Litigation ,
Interim Final Rules (IFR) ,
Out of Network Provider ,
Surprise Medical Bills ,
Texas ,
U.S. Treasury ,
Vacated
The old adage “you can’t get where you’re going unless you know where you are” has never seemed more true than when applied to the current mélange of healthcare transparency guidance. Fortunately, a fading relic from...more
11/10/2021
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Drug Pricing ,
Employee Benefits ,
Employer Group Health Plans ,
Final Rules ,
Office of Personnel Management (OPM) ,
Price Comparisons ,
Public Disclosure ,
Transparency ,
U.S. Treasury
This Client Advisory summarizes developments in the law governing employee benefit plans prompted by the COVID-19 pandemic. We explain what these developments mean for plan sponsors and highlight the need to adopt plan...more
8/19/2021
/ 401k ,
403(b) Plans ,
American Rescue Plan Act of 2021 ,
CARES Act ,
COBRA ,
Compensation & Benefits ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Mandates ,
Equal Employment Opportunity Commission (EEOC) ,
Executive Compensation ,
GINA ,
Health and Welfare Plans ,
IRS ,
Medicare ,
New Guidance ,
Paid Leave ,
Pharmacy Benefit Manager (PBM) ,
Reasonable Accommodation ,
Remote Working ,
Retirement Plan ,
Vaccinations