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HIPAA Privacy Rule Model Attestation for Reproductive Health Information

Earlier we discussed the Office for Civil Rights (“OCR”) of the US Department of Health and Human Services final rules relating to reproductive health care information (the “Final Rules”). In our prior blog we discussed that...more

ERISA Blog | Changes to the HIPAA Privacy Rules A Primer for Self-Insured Group Health Plans [Video]

The Office for Civil Rights (“OCR”) of the US Department of Health and Human Services recently released a final rule (“Final Rule”) to update the HIPAA Privacy Rules for reproductive health care information. The Final Rule...more

Changes to the HIPAA Privacy Rules – A Primer for Self-Insured Group Health Plans

The Office for Civil Rights (“OCR”) of the US Department of Health and Human Services recently released a final rule (“Final Rule”) to update the HIPAA Privacy Rules for reproductive health care information. The Final Rule...more

HHS Aligns Part 2 Rules with the HIPAA Privacy Rules – Effects on Self-Insured Plan Sponsors

In a December 2023 blog post, we discussed the HHS proposed revisions to the Part 2 regulations and that finalization of those regulations was imminent.  On February 8, 2024, HHS through the Substance Abuse and Mental Health...more

HHS Releases Privacy Rule Guidance Regarding Abortion-Related Disclosures

Following the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, the Department of Health and Human Service (HHS) has issued several pieces of guidance regarding protections for an individual’s...more

Biden Administration Signs Executive Order after Dobbs Decision

Since the Dobbs decision, employers and health plan sponsors have been scrambling to determine how they can assist employees and health plan participants in states that currently or will soon be restricting access to...more

HHS Proposes to Allow Health Plans to Exclude Drug Manufacturer Coupons from Annual Limits

HHS recently issued its proposed Notice of Benefit and Payment Parameters (“NBPP”) for the 2021 calendar year. The 2021 Proposed NBPP allows health plans, including self-insured group health plans, to voluntary count the...more

Departments Delay Implementation of Controversial HHS Prescription Drug Rule

In ACA FAQ Part 40, HHS, IRS and DOL (the "Departments") delayed the implementation of the controversial rule in HHS 2020 Notice of Benefit and Payment Parameters requiring health plans to credit to the out-of-pocket maximum...more

Are Manufacturer Drug Coupons and HDHPs a Good Fit

In our last blog past, we discussed the recent rule finalized by Health and Human Services regarding the calculation of the annual cost-sharing limits for health plan participants who receive financial assistance from drug...more

New HHS Rule Regarding Manufacturer Drug Coupons Impacts ACA Cost Sharing Limits

The Notice of Benefit and Payment Parameters for 2020 released by the Department of Health and Human Services (HHS) finalizes a proposed rule regarding the calculation of the annual cost-sharing limits for health plan...more

Now is a Good Time to Review Your HIPAA Policies

The HHS Office for Civil Rights (OCR) has announced it is increasing its investigations of breaches of unsecured protected health information (PHI) affecting fewer than 500 individuals. As a reminder, the HIPAA Breach...more

Revised SBCs Finalized (for use on or after April 2017)

Recently, we summarized the proposed revisions to the Summary of Benefits and Coverage template. This week, the agencies issued the final SBCs and related documents that must be used beginning on the first day of the first...more

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