The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....more
12/11/2023
/ Affordable Care Act ,
Co-payments ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employees ,
Employer Group Health Plans ,
Enforcement Guidance ,
Final Rules ,
Health Insurance ,
Healthcare ,
Non-Enforcement ,
Pharmaceutical Industry ,
Prescription Drugs ,
Rulemaking Process
Summary -
By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more
7/21/2023
/ Attestation Deadlines ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Gag Clauses ,
Health Care Providers ,
Health Insurance ,
HRA ,
Internal Revenue Code (IRC) ,
U.S. Treasury
The Fifth Circuit Court of Appeals has stayed the broad application of a district court decision that would have invalidated a number of preventive care requirements under the Affordable Care Act. As a result, health plans,...more
Summary -
To help individuals better understand the costs they will bear for medical care, the Consolidated Appropriations Act (CAA) requires health plan ID cards to include clear information about deductibles and...more
The U.S. Department of Labor issued guidance on April 7 about the new COBRA subsidy rules under the American Rescue Plan (ARP). However, the DOL left some significant questions unanswered....more
The new stimulus bill (the Consolidated Appropriations Act of 2021 or CAA) imposes new disclosure requirements for brokers and consultants providing services to ERISA health plans. The service providers are required to...more
In Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania, the Supreme Court this week upheld regulations issued by the U.S. Departments of Treasury, Labor, and Health and Human Services (the Departments) that...more
7/13/2020
/ Administrative Authority ,
Administrative Procedure Act ,
Affordable Care Act ,
Appeals ,
Contraceptive Coverage Mandate ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Employer Mandates ,
Employer Rights ,
HRSA ,
Injunctive Relief ,
Little Sisters of the Poor Saints Peter and Paul Home v Pennsylvania ,
Religious Exemption ,
Religious Freedom Restoration Act (RFRA) ,
Reversal ,
SCOTUS ,
Trump v Pennsylvania ,
U.S. Treasury
The Coronavirus, Aid, Relief, and Economic Security Act, or CARES Act, which passed the Senate last night, is Congress’s third legislative answer to the coronavirus pandemic. The CARES Act represents a heavily negotiated...more
The Internal Revenue Service (IRS) issued a notice that allows individuals to participate in a health savings account (HSA) while participating in a high deductible health plan (HDHP) that provides coverage for both the...more
3/16/2020
/ China ,
Clinical Laboratory Testing ,
Coronavirus/COVID-19 ,
Crisis Management ,
Deductibles ,
Emergency Management Plans ,
Emergency Response ,
Employee Benefits ,
Employer Group Health Plans ,
HDHP ,
Health Insurance ,
Health Savings Accounts ,
Infectious Diseases ,
IRS ,
Medical Benefits ,
Medical Examinations ,
New Guidance ,
Popular ,
Public Health
The U.S. Departments of the Treasury, Labor, and Health and Human Services have issued final regulations allowing employers to establish health reimbursement arrangements and certain other types of reimbursement plans...more
The U.S. District Court for the District of Columbia has set aside the most significant portions of the U.S. Department of Labor's (DOL) regulations on Association Health Plans (AHPs)....more
4/2/2019
/ Affordable Care Act ,
Association Health Plans ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Health Insurance ,
Healthcare Reform ,
Regulatory Requirements ,
Set-Asides ,
Trump Administration
The Equal Employment Opportunity Commission (EEOC) has formally withdrawn the provisions in its regulations governing wellness programs under the Americans with Disabilities Act (ADA) and the Genetic Information...more
The IRS has followed up on its recently proposed Health Reimbursement Arrangements (HRA) regulations with guidance on some open issues. Notice 2018-88 specifically addresses the interplay between HRAs and two Internal Revenue...more
The U.S. Departments of the Treasury, Labor, and Health and Human Services have jointly issued proposed regulations that envision a broad landscape for the use of health reimbursement arrangements (HRAs) and certain other...more
The U.S. Departments of the Treasury, Labor, and Health and Human Services have jointly issued final rules modifying the definition of short-term, limited-duration insurance (STLDI). STLDI provides health coverage that is...more
The U.S. Department of Labor (DOL) on Tuesday released final regulations modifying the Association Health Plan (AHP) rules to expand their availability for small and large employers and to address their affordability by...more
6/25/2018
/ Affordable Care Act ,
Association Health Plans ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Health Insurance ,
Healthcare Reform ,
MEWAs ,
Regulatory Reform ,
Regulatory Requirements
The IRS has announced that it will restore the family deduction limit for Health Savings Account (HSA) contributions to $6,900 for 2018. The IRS had previously set this limit last spring, but earlier this year announced that...more
Following a brief shutdown of the federal government, on February 9, Congress passed and President Donald J. Trump signed into law the Bipartisan Budget Act of 2018 (Budget Act), which provides Congress until March 23 to...more
2/19/2018
/ ACOs ,
Affordable Care Act ,
Bipartisan Budget Act ,
Children's Health Insurance Program (CHIP) ,
Employee Benefits ,
Employer Group Health Plans ,
Federal Budget ,
Hardship Distributions ,
Health Insurance ,
Healthcare Reform ,
IPAB ,
Medicare ,
Medicare Advantage ,
Medicare Part D ,
Retirement Plan ,
Telehealth
Following up on the direction provided by Executive Order 13813, the U.S. Department of Labor (DOL) has issued proposed regulations that would expand the ability of small employers to band together and provide coverage under...more
1/8/2018
/ Affordable Care Act ,
Association Health Plans ,
Compensation & Benefits ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Executive Orders ,
Health Insurance ,
Healthcare Reform ,
Regulatory Reform ,
Trump Administration
The IRS has announced its intent to begin enforcing the employer-shared responsibility provisions (otherwise known as the employer mandate or pay-or-play provisions) of the Affordable Care Act for the 2015 calendar year....more
After a brief lull in activity, recent developments are likely to involve all three branches of government in addressing issues under the Affordable Care Act....more
10/19/2017
/ Affordable Care Act ,
Contraceptive Coverage Mandate ,
Cost-Sharing ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Mandates ,
Executive Orders ,
Health Insurance ,
Healthcare Reform ,
Legislative Agendas ,
Proposed Legislation ,
Public Health Insurance Marketplace ,
Religious Exemption ,
Repeal ,
Subsidies ,
Trump Administration
The U.S. Department of Labor (DOL) recently released a draft model form for plan participants to request disclosures from group health plans and insurers about restrictions on mental health coverage. The form is designed to...more
The U.S. Departments of Labor, Health and Human Services, and the Treasury have issued a set of Frequently Asked Questions and Answers that, among other things, implement certain of the recommendations included in a report...more
11/7/2016
/ Affordable Care Act ,
Data Collection ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
Healthcare ,
Mental Health Parity Rule ,
MHPAEA ,
Opioid ,
Prescription Drugs ,
Tobacco ,
Tobacco-Cessation
The IRS has issued proposed regulations on the individual mandate reporting requirements under section 6055 of the Internal Revenue Code. To a significant degree, the new regulations reflect guidance previously published by...more
8/4/2016
/ Affordable Care Act ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
Healthcare ,
Individual Mandate ,
Internal Revenue Code (IRC) ,
IRS ,
Minimum Essential Coverage ,
Reporting Requirements ,
Section 6055 ,
Section 6056
The Equal Employment Opportunity Commission has published final regulations and a set of questions and answers on how the Americans with Disabilities Act (ADA) applies to employer-sponsored wellness programs that offer...more