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
On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...more
10/4/2023
/ Billing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Fees ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
No Surprises Act (NSA) ,
Out of Network Provider ,
Surprise Medical Bills ,
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
Although the No Surprises Act was signed into law almost three years ago and has been in effect for the past year and a half, there have been numerous delays in implementation and execution due to the complexity of elements...more
A recent string of lawsuits, regulatory guidance, and market trends have dramatically impacted the types of services that enjoy first dollar coverage under high deductible health plan (HDHP) and health savings account (HSA)...more
7/21/2023
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
HDHP ,
Health Care Providers ,
Health Insurance ,
Health Savings Accounts ,
Preventive Health Care ,
Telehealth ,
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
Takeaway Message. The Department of Labor (“DOL”) has recently issued model notices and forms that can be used to comply with the new subsidized COBRA requirements created by the American Rescue Plan Act of 2021 (“ARPA” or...more
Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued two notices that extended certain benefit plan deadlines for both employees/plan participants and for plan administrators as a result of...more
COBRA compliance requires extra attention right now. There has been a wave of litigation surrounding COBRA election notices. Regulatory agencies have extended certain COBRA deadlines due to the COVID-19 pandemic. And the...more
In April 2019, the Department of Health and Human Services (HHS) released guidance indicating that a health plan must include the value of financial assistance received from a drug manufacturer (often referred to as a...more
The Mental Health Parity and Addiction Equity Act (MHPAEA) prohibits health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD) benefits from imposing limitations on MH/SUD...more
7/9/2019
/ Addiction Equity Act ,
Benefit Plan Sponsors ,
Department of Labor (DOL) ,
EBSA ,
Final Rules ,
Health Care Providers ,
Health Insurance ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
Self-Funded Health Plans ,
Substance Abuse
In December 2016, the Department of Labor issued final regulations under ERISA governing claims procedures for group disability plans, which will become effective January 1, 2018. Generally, these regulations were drafted to...more
3/8/2017
/ Benefit Plan Sponsors ,
Claim Procedures ,
Denial of Benefits ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Impartiality ,
Long Term Disability Insurance ,
Rescission
The U.S. Department of Labor (DOL) released a new template for the Summary of Benefits and Coverage (SBC) last year. As background, the Affordable Care Act requires health plans and health insurers to annually distribute SBCs...more