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The CAA Prescription Drug Benefit Reporting Requirement

Summary - The Consolidated Appropriations Act, 2021 (CAA) requires group health plans and health insurers to submit information regarding the costs of prescription drug costs and other health care services each year to the...more

Health Plan Fiduciaries Must Solicit Information From Brokers and Consultants

Summary - The Consolidated Appropriations Act, 2021 (CAA) requires the disclosure of information to ensure that brokers and certain consultants receive no more than reasonable compensation for their services....more

Understanding the Mental Health Parity and Addiction Equity Act

Summary - This is the second briefing in our series on the Consolidated Appropriations Act, 2021 (CAA) and transparency regulations. It concerns a new rule under the Mental Health Parity and Addiction Equity Act (MHPAEA)...more

Temporary Enforcement Policy Addresses CAA's Health Plan Service Provider Disclosure Requirements

Summary - The U.S. Department of Labor (DOL) has issued a temporary enforcement policy to address frequently asked questions about the requirement for certain service providers to disclose direct and indirect compensation...more

Upcoming Compliance Deadlines for Health and Welfare Plans

Summary - Throughout 2020 and 2021, employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes arising from the COVID-19 pandemic and new health legislation. To...more

HHS Clarifies Applicability of HIPAA Privacy Rule to COVID-19 Vaccination Status Requests

The U.S. Department of Health and Human Services (HHS) released guidance to address how the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule applies to various entities’ requests for information...more

OCR’s HIPAA Resolution Agreements: the Year Thus Far

The Office of Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) has continued its enforcement of HIPAA’s privacy and security rules in the new administration, announcing a number of settlements of...more

ARP: Employee Benefits and Executive Compensation

The American Rescue Plan (ARP) will have significant and immediate impacts on employee benefit plans, employers, and other plan sponsors and plan administrators. ...more

DOL Issues Guidance for Locating Missing Participants and Beneficiaries

Summary - The United States Department of Labor (DOL) issued guidance to assist plan fiduciaries in fulfilling their ongoing obligation of locating missing or nonresponsive participants and distributing benefits to such...more

HHS Announces Eight HIPAA Settlements

Following a very quiet start to HIPAA settlement activity in 2020, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently announced eight settlements with covered entities and business...more

Court Issues Injunction Against Revised ACA Nondiscrimination Rules

The U.S. District Court for the Eastern District of New York blocked federal rules seeking to remove nondiscrimination protections for health care patients. The blocked rules would have removed protections against...more

DOL and Treasury Extend Benefits-Related Deadlines

To reduce the risk that participants will lose benefits during the COVID-19 outbreak because they fail to meet certain procedural requirements, the U.S. Departments of Labor and the Treasury announced the extension of a...more

New Jersey Extends Deadline for Health Coverage Filings

On March 19, 2020, the New Jersey Department of Treasury announced that it extended the deadline for applicable coverage providers to file Forms 1095 with the New Jersey Division of Taxation from March 31, 2020, to May 15,...more

OCR Hits Health System with $2.2M Fine for HIPAA Violations

The U.S. Department of Health and Human Services Office of Civil Rights (OCR) imposed $2,154,000 in civil monetary penalties against Jackson Health System in Florida for failing to meet HIPAA privacy and security...more

OCR Announces $10,000 Settlement for Disclosure of Patients’ PHI through Social Media

The Office for Civil Rights (OCR) at the Department of Health and Human Services announced it reached a settlement with Elite Dental Associates of Dallas (Elite) to resolve a complaint alleging Elite impermissibly disclosed a...more

U.S. District Court Upholds Short-Term Limited Duration Insurance Rule

The U.S. District Court for the District of Columbia upheld a rule that expanded the maximum length of time for short-term, limited duration insurance (STLDI).  STLDI is coverage that lasts a limited period of time and is...more

IRS Expands Determination Letter and Self-Correction Programs

The IRS announced yesterday that it will expand its determination letter program for tax-qualified retirement plans. Under previous IRS procedures, a plan sponsor could submit its plan document to the IRS, and the IRS would...more

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