Federal regulators recently indicated they will not enforce parts of the final regulations issued in September 2024 under the Mental Health Parity and Addiction Equity Act (MHPAEA) and may soon propose new rules altogether....more
Only weeks after the principal effective date for the final 2024 federal mental health parity rules for employer-sponsored health benefit plans, those rules—and specifically some key features that are frustrating...more
2/21/2025
/ Administrative Procedure Act ,
Benefit Plan Sponsors ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Final Rules ,
Mental Health ,
MHPAEA ,
Pending Litigation ,
Regulatory Requirements
Even as high-priority issues such as diversity, equity, and inclusion (DEI), immigration, and Ukraine take center stage in the first months of the new presidential administration, many employers are wondering what the next...more
The wait is over, and now the work begins for health plan sponsors.
Much-anticipated final rules implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) were...more
9/19/2024
/ Benefit Plan Sponsors ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Health Insurance ,
HMOs ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Out of Network Provider ,
Outpatient Services ,
Substance Abuse
Now you know.
It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more
8/4/2023
/ Benefit Plan Sponsors ,
Centers for Medicare & Medicaid Services (CMS) ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Health Insurance ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Rules ,
Regulatory Agenda ,
U.S. Treasury
Employers have some new clarity on the No Surprises Act rules on out-of-network providers and charges under new guidance from the U.S. Department of Labor, U.S. Department of the Treasury, and the U.S. Department of Health...more
Employers, at least for now, may have some relief from some of the Affordable Care Act (ACA) requirements to cover preventive care services without cost sharing under a nationwide injunction issued March 30, 2023, by a...more
4/20/2023
/ ACIP ,
Affordable Care Act ,
Appointments Clause ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Employer Group Health Plans ,
Health Insurance ,
HRSA ,
HSA ,
Injunctions ,
Preventive Health Care ,
Screening Procedures
What does the April 10, 2023, early end of the COVID-19 National Emergency declaration mean for employer health plans?
Well, nothing, actually....more
As employers plan for the impact of the anticipated May 11, 2023, end of the two federal COVID-19 emergency orders, they have some important new clarity on test and vaccine coverage and on how to unwind COVID-19–era extended...more
4/4/2023
/ Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Health and Human Services (HHS) ,
Health Savings Accounts ,
New Guidance ,
Public Health Emergency ,
Secretary of HHS ,
Vaccinations ,
Virus Testing
Employers can’t say they weren’t warned.
For the second time in six months, frequently asked question (FAQ) guidance from federal regulators is calling attention to the requirement that employer-sponsored health...more
8/5/2022
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Contraceptive Coverage Mandate ,
Contraceptives ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
New Guidance ,
Preemption
On February 4, 2022, the U.S. Department of Labor (DOL), U.S. Department of the Treasury, and U.S. Department of Health and Human Services (HHS) issued subregulatory guidance that provides greater flexibility and clarifies a...more
2/9/2022
/ Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Families First Coronavirus Response Act (FFCRA) ,
Flexible Savings Accounts (FSAs) ,
Guidance Update ,
Health Insurance ,
HSA ,
Over The Counter Drugs (OTC) ,
Reimbursements ,
Virus Testing
Employer health plans and health insurers will be required to cover over-the-counter (OTC) COVID-19 tests, even without a health care provider’s order or an individualized clinical assessment, and generally without cost...more
1/12/2022
/ Benefit Plan Sponsors ,
Biden Administration ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Health Insurance ,
New Guidance ,
Popular ,
Virus Testing ,
Workplace Safety
Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data - but no more time to comply with - daunting prescription drug cost reporting requirements in the...more
12/16/2021
/ Benefit Plan Sponsors ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Drug Pricing ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Interim Final Rules (IFR) ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs ,
Rebates ,
Reporting Requirements ,
U.S. Treasury ,
Year-End Compliance Checklist
Employers that are considering imposing health plan premium surcharges to encourage their employees to get vaccinated have clearer guidance on how to do so without running afoul of the nondiscrimination rules under the Health...more
10/7/2021
/ Affordable Care Act ,
CARES Act ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Guidance Update ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Non-Discrimination Rules ,
Plan Participants ,
Surcharges ,
Vaccinations
Employer-sponsored health plans can add air ambulance claims reporting to the list of required disclosures that will go into effect in the next several years.
Under proposed regulations published September 16, 2021, by...more
9/30/2021
/ Ambulance Providers ,
Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Disclosure Requirements ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Enforcement ,
Insurance Claims ,
Out of Network Provider ,
Penalties ,
Surprise Medical Bills
New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more
8/24/2021
/ Affordable Care Act ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Health Insurance ,
Mental Health Parity Rule ,
New Guidance ,
Reporting Requirements ,
Surprise Medical Bills ,
U.S. Treasury
Plan participants can be hit with surprise medical bills when they receive care from out-of-network providers. Sometimes, this happens when participants do not know that the care they are receiving is from an out-of-network...more
7/22/2021
/ Benefit Plan Sponsors ,
Consolidated Appropriations Act (CAA) ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Employer Group Health Plans ,
Interim Final Rules (IFR) ,
New Guidance ,
Out of Network Provider ,
Self-Insured Health Plans ,
Surprise Medical Bills ,
U.S. Treasury
A federal court ruling staying key parts of new Affordable Care Act (ACA) regulations in light of the landmark Supreme Court of the United States ruling on sexual orientation and gender identity will provide little certainty...more
Employers have more clarity on COVID-19 testing coverage requirements - including new details on at-home tests, return-to-work testing, and out-of-network pricing - under new guidance that the U.S. Department of Health and...more
Most employer-sponsored health plans will be exempt from the primary Affordable Care Act (ACA) provision governing race, color, age, sex, disability, and national origin discrimination under new final rules issued by the U.S....more
Employers now have greater clarity on how the new federal requirements covering COVID-19 testing and diagnosis apply to their group health plans, under guidance issued by the U.S. Department of Labor, U.S. Department of...more
Employer-sponsored health plans and health insurers may be required to post online - and to provide participants upon request - a range of pricing and cost-sharing information beginning in 2021.
Proposed Affordable Care...more
11/26/2019
/ Affordable Care Act ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Employer Group Health Plans ,
Health Care Providers ,
Healthcare Costs ,
Hospitals ,
Out-of-Pocket Expenses ,
Proposed Regulation ,
Proposed Rules ,
Public Comment ,
Transparency
Employer plans will still be able to exclude the value of drug manufacturer coupons from annual out-of-pocket maximums, even when no generic equivalent is available, under new guidance from the Department of Labor, Department...more
8/28/2019
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Co-payments ,
Deductibles ,
Department of Health and Human Services (HHS) ,
Generic Drugs ,
Health Insurance ,
IRS ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs ,
U.S. Treasury
The Department of Labor (DOL), the Department of the Treasury, and the Department of Health and Human Services (HHS) are making good on their promise to issue more guidance and to aggressively enforce the federal Mental...more
5/14/2018
/ 21st Century Cures Initiative ,
Affordable Care Act ,
Benefit Plan Sponsors ,
Comment Period ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Health Insurance ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
New Guidance
Any privately held, for-profit company could potentially be exempt from the Affordable Care Act’s (ACA) requirement to provide comprehensive contraceptive coverage without cost-sharing based on the company’s “sincerely held...more