On Monday, September 9, 2024, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued their final rule regarding the nonquantitative treatment limitation (NQTL) comparative analysis...more
9/11/2024
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Final Rules ,
Health Insurance ,
Healthcare ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Rules ,
U.S. Treasury
Seyfarth Synopsis: Following years of back and forth, new final rules were published by the Department of Health and Human Services (HHS) on May 6, 2024 reinstituting the Department’s interpretation that the prohibition on...more
5/21/2024
/ Affordable Care Act ,
Covered Entities ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Final Rules ,
Gender Identity ,
Health Insurance ,
LGBTQ ,
OCR ,
Section 1557 ,
Sex Discrimination ,
Transgender
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
Seyfarth Synopsis: Last week, the Alabama Supreme Court ruled that cryogenically frozen embryos are children and are protected from destruction under state law. This is the latest in a series of post-Dobbs judicial rulings...more
2/28/2024
/ Abortion ,
AL Supreme Court ,
Dobbs v. Jackson Women’s Health Organization ,
Employee Benefits ,
Employer Liability Issues ,
Family Planning Clinics ,
Fertility Treatments ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Human Embryos ,
Internal Revenue Code (IRC) ,
Patient Access ,
Reproductive Healthcare Issues ,
Wrongful Death
Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may...more
Seyfarth Synopsis: Following over a decade of protracted litigation over the Affordable Care Act, and several failed attempts by Congress to get rid of the ACA entirely, a Texas federal district court ruled on March 30, 2023...more
Seyfarth Synopsis: The No Surprises Act (the “Act”) was part of the Consolidated Appropriations Act of 2021 signed into law last December 2020. The Act was aimed at protecting insured individuals from getting a bill from a...more
Synopsis: For years, employers have struggled to understand what level of incentives in wellness programs might be considered “voluntary” under the Americans with Disabilities Act (ADA). ...more
Seyfarth Synopsis: One of many COVID-19 benefits-related concerns focused on the ability of individuals covered under High Deductible Health Plans to have services to diagnose or treat the coronavirus covered before their...more
3/13/2020
/ Clinical Laboratory Testing ,
Coronavirus/COVID-19 ,
Cost-Sharing ,
Crisis Management ,
Deductible Expenses ,
Emergency Response ,
Employee Benefits ,
HDHP ,
Health and Safety ,
Health Insurance ,
HSA ,
Infectious Diseases ,
IRS ,
New Guidance ,
Public Health ,
Relief Measures
Seyfarth Synopsis: Because everything has a coronavirus angle now….this blog post covers various issues and considerations plan sponsors and administrators should keep in mind as the coronavirus outbreak continues to...more
3/6/2020
/ Americans with Disabilities Act (ADA) ,
Benefit Plan Sponsors ,
China ,
Coronavirus/COVID-19 ,
Crisis Management ,
Disclosure Requirements ,
Electronic Protected Health Information (ePHI) ,
Employee Benefits ,
Employee Privacy Rights ,
Employee Retirement Income Security Act (ERISA) ,
Employment Policies ,
Government Agencies ,
Health and Safety ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Infectious Diseases ,
OSHA ,
Personal Protective Equipment ,
PHI ,
Plan Administrators ,
Public Health ,
Workplace Safety
Seyfarth Synopsis: Recent changes to the federal rules governing confidentiality of substance use disorder (SUD) patient records may require updates to agreements between group health plans and their third-party vendors....more
1/31/2020
/ Confidential Information ,
Deadlines ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Medicaid ,
Medical Records ,
Medicare ,
PHI ,
SAMHSA ,
Service Agreements ,
Substance Abuse ,
Third-Party Relationships
Last year, the IRS published the calendar year 2018 health savings account (HSA) contribution limits for individual and family coverage. Rev. Proc. 2017-37, I.R.B. 2017-21 (5/4/2017). ...more
On Tuesday, August 22, the US District Court for the District of Columbia ordered the EEOC to revisit its controversial rules placing certain limits on employer-sponsored wellness programs under the Americans with...more
8/30/2017
/ AARP ,
Affordable Care Act ,
Americans with Disabilities Act (ADA) ,
Discrimination ,
Employee Benefits ,
Employer Group Health Plans ,
Equal Employment Opportunity Commission (EEOC) ,
Genetic Discrimination ,
GINA ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Non-Discrimination Rules ,
Wellness Programs
Seyfarth Synopsis: The Republican’s efforts to repeal and replace the Affordable Care Act may be dead on arrival. The defection of a total of four Senators from support of BCRA 2.0 means that bill has no chance of passage. ...more
Seyfarth Synopsis: The epicenter of the health care repeal and replace effort has moved from the House of Representatives to the Senate. After several weeks of drafting behind closed doors, the Senate introduced the Better...more
This is the one hundred and ninth issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of...more
5/9/2017
/ Affordable Care Act ,
American Health Care Act (AHCA) ,
Cadillac Tax ,
CBO Report ,
Employer Mandates ,
Essential Health Benefits ,
Flexible Spending Accounts ,
Health Insurance ,
Health Insurance Exchanges ,
Health Savings Accounts ,
Medicaid ,
Medicare ,
Premium Subsidies ,
Proposed Legislation ,
Repeal ,
Trump Administration
This is the one hundred and eighth issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of...more
This is the one hundred and sixth issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of...more
3/8/2017
/ Abortion ,
Affordable Care Act ,
Employer Mandates ,
Excise Tax ,
Form 1094 ,
Form 1095 ,
Health Insurance ,
Healthcare Reform ,
Prescription Drugs ,
Proposed Legislation ,
Reporting Requirements ,
Tanning Salons ,
Trump Administration