The Mental Health Parity and Addiction Equity Act and its implementing regulations and guidance (MHPAEA) prohibit health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD)...more
9/19/2024
/ Compliance ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary ,
Final Rules ,
Health Plan Sponsors ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Substance Abuse ,
U.S. Treasury
The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...more
9/21/2023
/ Consolidated Appropriations Act (CAA) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Mental Health Parity Rule ,
MHPAEA ,
New Guidance ,
NQTLs ,
Opioid ,
Proposed Rules ,
Substance Abuse ,
U.S. Treasury
Under the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers are required to annually attest that they are in compliance with the CAA’s gag clause prohibition. On a high level, the...more
On January 30th, President Biden announced his intention to end both the COVID-19 national emergency and the COVID-19 public health emergency (together, the “Emergency Declarations”) effective May 11, 2023. The Emergency...more
On December 23, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) provided welcome relief in the form of an FAQ regarding the Prescription Drug Data Collection (RxDC)...more
Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...more
10/19/2022
/ Deadlines ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
GAO ,
HCPCS ,
Health Insurance ,
Health Plan Sponsors ,
No Surprises Act (NSA) ,
Proposed Rules ,
Third-Party ,
U.S. Treasury
Over the last two years, behavioral health (BH) has been one of the biggest growth areas in the health care ecosystem, fueled by the Public Health Emergency (PHE) but in many ways an ignored, overlooked, understaffed, and...more
4/1/2022
/ CMMI ,
Consolidated Appropriations Act (CAA) ,
DEA ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Health Care Providers ,
Investors ,
Medicaid ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Out of Network Provider ,
Public Health Emergency ,
Reimbursements ,
Substance Abuse ,
Surprise Medical Bills
On January 25, 2022, the U.S. Departments of Labor (“DOL”), Treasury, and Health and Human Services (the “Departments”) provided a report (the “Report”) on Mental Health Parity and Addiction Equity Act (“MHPAEA”) compliance...more
The Consolidated Appropriations Act, 2021 (CAA) generally requires group health plan sponsors to request and review fee information from their plan service providers who provide brokerage services or consulting. This fee...more
The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) set forth new compensation disclosure requirements that apply to service providers who provide “brokerage services” or “consulting” to group health plans...more
1/14/2022
/ Compensation ,
Consolidated Appropriations Act (CAA) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Assistance Programs ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Flexible Savings Accounts (FSAs) ,
HRA ,
Pharmacy Benefit Manager (PBM) ,
Third-Party
Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more
Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more
Embedded in the Consolidated Appropriations Act, 2021 (the “CAA”) is a new obligation for group health plan sponsors and insurers that provide health insurance to document that their group health plan or insurance policy...more
Earlier this year, we discussed the lifetime income disclosure requirement that was included in the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). When the disclosure requirement becomes...more
9/17/2020
/ Annuities ,
Compliance Dates ,
Defined Contribution Plans ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Federal Register ,
Interim Final Rules (IFR) ,
Lifetime Income Disclosures ,
Retirement Plan ,
SECURE Act