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
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
The Consolidated Appropriations Act of 2023 (2023 CAA) further extends the HSA safe harbor allowing high deductible health plans (HDHPs) to offer first dollar coverage of telehealth services without ruining HDHP members’...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
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, Public Law 116-260 (CAA) sets forth new compensation disclosure requirements that apply to brokers and consultants with respect to both fully-insured and self-insured group health...more
On September 30, 2021, the U.S. Departments of Health and Human Services (HHS), Labor and Treasury (collectively, the Departments) along with the Office of Management and Budget released “Requirements Related to Surprise...more
Over the last several years, both the federal government and a number of state legislatures have sought to find a solution to the billing by out-of-network providers, referred to as “Out of Network Billing” (OON Billing) and...more
Recent court trends suggest that preemption under the Employee Retirement Income Security Act (ERISA) may not apply to certain state laws that regulate pharmacy benefit managers (PBMs), including state laws governing Maximum...more
6/16/2021
/ Drug Pricing ,
Employee Retirement Income Security Act (ERISA) ,
Health Insurance ,
Pharmaceutical Industry ,
Pharmacies ,
Pharmacy Benefit Manager (PBM) ,
Preemption ,
Prescription Drug Coverage ,
Prescription Drugs ,
Rutledge v Pharmaceutical Care Management Association ,
SCOTUS
On March 27, 2020, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) into law. The CARES Act contains several provisions affecting healthcare benefits and the expansion of...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which was signed by the President on March 27, 2020, includes several provisions affecting group health plans, as discussed below.
Health Plan Rules and...more
3/31/2020
/ CARES Act ,
Clinical Laboratory Testing ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Federal Funding ,
Financial Stimulus ,
Health Care Providers ,
Health Insurance ,
Hospitals ,
Inpatient Prospective Payment System (IPPS) ,
Medical Supplies ,
Medicare ,
Prescription Drugs ,
Public Health Emergency ,
Telehealth
Takeaway Message: The IRS has recently concluded that the Affordable Care Act’s (the “ACA”) employer mandate is an ongoing tax liability which cannot be extinguished with the passage of time. In other words, the IRS has no...more
Background. These days, almost all employer-sponsored group health plans require an employee (and any dependents) covered under the plan (each are referred to as a “member”) to pay “out-of-pocket” for covered expenses in the...more
9/10/2019
/ Benefit Plan Sponsors ,
Co-payments ,
Coupons ,
Deductibles ,
Department of Health and Human Services (HHS) ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
Out-of-Pocket Expenses ,
Pharmaceutical Industry ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs
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
Effective January 1, 2020, employers may put aside pre-tax funds into a health reimbursement arrangement (“HRA”) that can be used by an employee to pay for premiums and other out-of-pocket costs related to the purchase of an...more
The “Bottom Line” -
Employers will have until March 2, 2018 to furnish Form 1095-C (“Employer-Provided Health Insurance Offer and Coverage”) to employees.,,...more
It’s official. The IRS has finally begun the process of collecting penalties under the Affordable Care Act’s (“ACA”) employer shared responsibility provisions, better known as the “employer mandate.” The IRS has started...more
Congress is now back in session and, once again, focus has turned to health care. With all eyes on returning health care reform to the forefront, a flurry of activity has sparked new legislative efforts including the...more
9/19/2017
/ Affordable Care Act ,
Federal Grants ,
Health Insurance ,
Health Savings Accounts ,
Healthcare Reform ,
Legislative Agendas ,
Medicaid Expansion ,
Medicare ,
Political Parties ,
Repeal ,
Trump Administration
On July 13th, the Senate released the updated version of the Better Care Reconciliation Act (BCRA) of 2017. While the new version makes some significant changes to the original Senate proposal, the major components of the...more
After weeks of secrecy, the Senate has released a discussion draft of legislation that is the counterpart of the American Health Care Act (AHCA) previously passed by the House. The Senate legislation, entitled the Better Care...more
6/28/2017
/ Affordable Care Act ,
Block Grants ,
Cadillac Tax ,
Congressional Budget Office ,
Cost-Sharing ,
Dependents ,
Essential Health Benefits ,
Flexible Spending Accounts ,
Health Insurance ,
Health Savings Accounts ,
Healthcare Reform ,
High Risk Pools ,
Legislative Agendas ,
Medicaid ,
Medicaid Expansion ,
Medicare ,
Penalties ,
Planned Parenthood ,
Political Parties ,
Preexisting Conditions ,
Prescription Drugs ,
Proposed Legislation ,
Repeal ,
Tax Benefits ,
Trump Administration ,
Waivers
On Monday, two House committees with oversight over health care and taxation, Energy and Commerce and Ways and Means, released draft reconciliation bills designed to repeal and alter significant portions of the Patient...more
3/9/2017
/ Affordable Care Act ,
Employer Mandates ,
Health Insurance ,
Health Savings Accounts ,
Individual Mandate ,
Legislative Agendas ,
Medicaid ,
Planned Parenthood ,
Proposed Legislation ,
Repeal ,
State Health Insurance Exchanges ,
Tax Penalties
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