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HHS to Enforce Section 1557 of the Affordable Care Act to Prohibit Discrimination Based on Sexual Orientation and Gender Identity

Summary - Federal agencies will enforce Section 1557 of the Affordable Care Act to prohibit discrimination based on sexual orientation or gender identity. The announcement reverses an effort under the previous...more

Q&A: COBRA Subsidies Under the American Rescue Plan

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

ARP: COBRA Premium Assistance

The United States Department of Labor has issued much anticipated guidance and model forms under the COBRA subsidy rules introduced by the American Rescue Plan (ARP). The FAQ guidance and forms clarify some issues that...more

ARP: Employee Benefits and Executive Compensation

The American Rescue Plan (ARP) will have significant and immediate impacts on employee benefit plans, employers, and other plan sponsors and plan administrators. ...more

A Rolling Extension: New Guidance on Employee Benefit Deadlines

The U.S. Department of Labor issued a notice that addresses how the extension announced last year for certain employee benefit deadlines will apply now that the commencement date for the extension has passed its one-year...more

COVID-19 Vaccine Programs: EEOC Withdraws Proposed Rules on Employer Wellness Incentives

Many employers implementing vaccination programs for their employees have needed to consider whether those programs should be treated as employee wellness programs. ...more

IRS Issues New Flexible Spending Account Rules

The IRS issued a notice that addresses many of the questions employers have raised about flexible spending accounts (FSAs) in view of the new rules set forth in the Consolidated Appropriations Act (CAA)....more

EEOC Withdraws Proposed ADA Wellness Program Rules, Leaving Vaccine Incentives in Limbo

As employers wrestle with whether to require vaccines for employees or how to encourage employees to get vaccinated voluntarily, many companies are implementing incentive programs that provide gifts, paid time off and even...more

A Fast Start: 2021 Begins With Major HIPAA Developments

The new year began with an unusual amount of activity related to the Health Insurance Portability and Accountability Act (HIPAA). Health care providers, health plans, health care clearinghouses, and business associates...more

COBRA Subsidies Included in Latest Stimulus Proposal

Group health plan sponsors and administrators may soon need to introduce changes to their offer of continued coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). The House Education and Labor...more

A Second Proposal: EEOC Issues New Guidance on Nondiscrimination for Wellness Programs

Summary - The Equal Employment Opportunity Commission (EEOC) announced it will issue much-anticipated guidance that revises its nondiscrimination rules for wellness programs under the Americans with Disabilities Act (ADA)...more

Stimulus Bill Adds New Disclosure Requirements for Consultants and Brokers to ERISA Health Plans

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

OCR Issues Guidance Related to PHI Disclosures During COVID

On December 18, 2020, the United States Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) issued guidance specific to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and...more

New Stimulus Law Seeks to Strengthen Mental Health Parity Compliance

This alert is the latest in a series from our Employee Benefits and Executive Compensation and Health Care Practice Groups about the most recent federal stimulus bill. We provided an overview of how the law addresses new...more

New Stimulus Deal: Health Care Cost Transparency Rules

On December 27, 2020, President Trump signed Congress’ most recent stimulus bill into law, covering $900 billion in economic relief for businesses and individuals impacted by the COVID-19 pandemic. The law addresses new...more

New Stimulus Deal: A Little More Flexibility for Flexible Spending Arrangements

The stimulus package that President Trump signed includes several provisions of significance to employee benefit plans, including measures that respond to the effects of the COVID-19 pandemic on health and dependent care...more

New Stimulus Deal: Overview of Major Provisions Impacting Businesses and Individuals

Congress passed additional COVID-19 relief legislation (H.R. 133) on Monday evening, December 21, 2020. Today, President Trump is expected to sign the deal, which includes a $900 billion economic stimulus package that will...more

Supreme Court Finds ERISA Does Not Preempt State Prescription Drug Pricing Law

Summary The U.S. Supreme Court unanimously upheld an Arkansas statute that regulates the price that pharmacy benefit managers (PBMs) pay retail pharmacies for prescription drugs.   ...more

Year-End COVID-19 Considerations for Health and Welfare Plans

Summary - COVID-19 has dominated the agenda for health and welfare benefits in 2020. From suspended deadlines to mid-year election changes to enhanced cost-free coverage, the pandemic has resulted in significant changes to...more

Hospitals Beware: A Cyberattack Alert

The Cybersecurity Infrastructure Security Agency, Federal Bureau of Investigation, and Department of Health and Human Services have jointly posted an advisory to warn hospitals and other health care providers about the threat...more

HHS Announces Eight HIPAA Settlements

Following a very quiet start to HIPAA settlement activity in 2020, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently announced eight settlements with covered entities and business...more

HHS Issues HIPAA Guidance on Contacting Survivors of COVID-19 About Plasma Donation

The Office of Civil Rights of the U.S. Department of Health and Human Services has issued guidance clarifying how HIPAA’s Privacy Rule permits covered entities (in particular, health care providers and health plans) or their...more

Court Issues Injunction Against Revised ACA Nondiscrimination Rules

The U.S. District Court for the Eastern District of New York blocked federal rules seeking to remove nondiscrimination protections for health care patients. The blocked rules would have removed protections against...more

Short-Term Limited Duration Insurance Rule Upheld

The U.S. Court of Appeals for the District of Columbia Circuit upheld the final regulations issued by the Trump administration that increased the availability of short term, limited duration insurance (STLDI). ...more

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