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
For the past few years, we have encouraged plan sponsors to focus on matters of fiduciary governance for their health and welfare benefit plans (see our 2021 blog post). Yet many plan sponsors overlook the fact that the...more
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
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
The IRS recently issued Notice 2021-31, which provides much sought-after detail regarding the contours and operation of the temporary premium subsidy for COBRA continuation coverage available through the American Rescue Plan...more
5/25/2021
/ American Rescue Plan Act of 2021 ,
Applications ,
COBRA ,
Coronavirus/COVID-19 ,
Covered Employees ,
Department of Labor (DOL) ,
Eligibility ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
IRS ,
Premium Subsidies ,
Tax Credits
This Client Advisory highlights important developments in the law governing employee benefit plans over the past year. It offers insight into what these developments mean for employers and plan sponsors and previews...more
12/18/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Executive Compensation ,
Families First Coronavirus Response Act (FFCRA) ,
Filing Deadlines ,
IRS ,
New Rules ,
Paid Leave ,
Retirement Plan ,
SECURE Act
The COVID-19 pandemic has forced us to find new ways to work through digital technology. Now, more than ever, an enormous percentage of our communications occur over the phone and online. The Department of Labor’s recent...more
This Client Advisory highlights important developments in the law governing employee benefit plans and executive compensation over the past year. It offers insight into what these developments mean for employers and plan...more
12/18/2019
/ 401k ,
403(b) Plans ,
Affordable Care Act ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HRA ,
IRS ,
New Rules ,
Pensions ,
Proposed Regulation