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IRS Releases 2024 Limits for Health and Welfare and Related Plans

Seyfarth Synopsis: The IRS has announced an increase to the applicable dollar amount for determining the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2024 as well as other health and welfare limits....more

The Benefits of Flying into SFO; Employees Have Free Family Health Insurance – For Now

Seyfarth Synopsis: In August, the Ninth Circuit Court of Appeals revived a challenge by Airlines for America (“A4A”), to San Francisco’s Healthy Airport Ordinance (the “Ordinance”), which requires airlines that use the San...more

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Mental Health Parody: In A Cruel Prank, Agencies Respond to Employer Pleas for Guidance with More Stringent Regulations

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

HSA Holders Lament the End of the Era of Free Invasive Nasal Swabs: IRS to Remove COVID Exemption for HDHPs

Seyfarth Synopsis: In light of the end of the COVID-19 National Emergency and Public Health Emergency, the Internal Revenue Service (“IRS”) has announced the end of prior COVID-19-related special rules for health plan...more

New Guidance on Gag Clause Attestation

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

Agency FAQs Reveal Employers Continue to Struggle with No Surprises Act & Transparency in Coverage Implementation

Seyfarth Synopsis: With staggered effective dates continuing over the course of the next several years, the No Surprises Act (NSA) and Transparency in Coverage requirements impose a number of additional compliance...more

If You Can Find an At-Home COVID-19 Test, Your Plan Must Now Pay For It

Seyfarth Synopsis: Since March 18, 2020, group health plans have been required to provide benefits for certain items and services related to testing for or diagnosis of COVID-19 during the applicable emergency period - see...more

IRS Announces PCORI Fee for 2022

Seyfarth Synopsis: The IRS has announced the adjustment to the applicable dollar amount for the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2022....more

Freedom Ain’t Free. COBRA, On the Other Hand…

Seyfarth Synopsis: The latest COVID relief bill, the American Rescue Plan Act (ARPA), provides for a 100% COBRA premium subsidy from April 1, 2021 through September 30, 2021. ARPA, which was signed into law by President...more

EEOC Wellness Rules Proposed, Water Bottle Enthusiasts Rejoice

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

HHS Proposes Changes to HIPAA Privacy Rules Affecting Group Health Plans

Seyfarth Synopsis: The Department of Health and Human Services (HHS) has issued a Notice of Proposed Rulemaking (NPRM) to modify the HIPAA Privacy Rule that protects the privacy and security of individuals’ protected health...more

Final Rule regarding Transparency in Coverage for Health Care Services

Seyfarth Comments: The final Transparency in Coverage Rule was published jointly by the Departments of Health and Human Services, Treasury, and Labor on November 12, 2020. The Rule aims to increase transparency in...more

Don’t Miss The July 31 Deadline

Seyfarth Synopsis:  The IRS announced the new rate for calculating the PCORI fee and provided some transition relief, but did not extend the deadline of July 31st for paying the fee. In May, the IRS issued Rev. Proc. 2020-32...more

Oh What a Relief It Is - For Health Plan Participants

Seyfarth Synopsis: On Tuesday, shortly after the IRS extended deadline relief to employee benefit plans, the U.S. Department of Labor granted its own relief for a number of deadlines related to the administration of employee...more

Thought You Paid Your Last PCORI Fee? Wrong!

Seyfarth Synopsis: We previously blogged that the so-called Cadillac tax was movin’ out. Well, the Patient-Centered Outcomes Research Institute (“PCORI”) fee is moving back in. On December 20th, the President signed the...more

Cadillac Tax is Movin’ Out

Seyfarth Synopsis: Although it is not law yet, according to the must-pass spending legislation passed by both the House and Senate, it looks like the infamous Cadillac Tax and the Annual Fee on Health Insurance Providers (HIP...more

Take Note: EEOC Vacates the Incentive Sections of its Final Wellness Regulations

Seyfarth Synopsis: The EEOC has withdrawn the incentive provisions in its ADA and GINA wellness program regulations. The remaining provisions have less bite as a consequence, especially in the ADA context. But HIPAA wellness...more

Relief Provided for 2018 Family HSA Contribution Limit

On April 26, 2018 the IRS issued Revenue Procedure 2018-27 providing transition relief for the 2018 limit on Health Savings Account (“HSA”) contributions for family coverage. The guidance allows individuals to continue to...more

IRS Retroactively Reduces HSA Contribution Limit; Transition Relief May Follow

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

Issue 117: DOL Issues Proposed Rules On Association Health Plans

This is the one hundred and seventeenth 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...more

Issue 116: Due Date Extended For Employers To Provide Reports To Employees

This is the one hundred and sixteenth 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

Issue 115: Ready or Not, Here Come ACA Employer Mandate Penalty Notices

This is the one hundred and fifteenth 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

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