K&L Gates Triage: An Insider’s Perspective on the Health Care Debate in Washington, DC
On April 29, 2024, the U.S. Department of Labor (the “DOL”) issued a final rule (the “Final Rule”) rescinding the 2018 Association Health Plan rule (“2018 AHP Rule”), thereby marking a return to the more rigid pre-2018...more
The U.S. Department of Labor (DOL)’s Employee Benefits Security Administration (EBSA) has issued a Notice of Proposed Rulemaking that would rescind a 2018 DOL rule entitled “Definition of Employee – Association Health Plans,”...more
2020 saw the courts continuing to play an important role in health policy with several notable lawsuits related to the Affordable Care Act (ACA). Several other Trump administration policies were challenged, including Medicare...more
In the opening days of his administration, President Biden has signed a flurry of Executive Orders impacting multiple sectors of the U.S. economy. This article summarizes the Orders that impact employee benefits and...more
On April 29, 2019, the United States Department of Labor (the “DOL”) released a policy statement providing transitional relief from the potential adverse consequences arising from a District Court’s vacating portions of the...more
As we predicted in our last Deep Dive, the Department of Labor (DOL) has appealed the District Court for the District of Columbia’s ruling in State of New York, et al. v. United States Department of Labor, et al. which...more
On March 28, 2019, the Federal District Court for the District of Columbia issued an opinion and order vacating key portions of the Department of Labor’s regulation, published in June 2018, which had expanded the definition...more
Judge John Bates of the US District Court for the District of Columbia recently struck down two parts of the US Department of Labor’s (DOL’s) final regulations on Association Health Plans (AHPs). On March 28, Judge Bates...more
On March 28, a District of Columbia federal court agreed with a New York-led challenge by a group of 11 states and the District of Columbia and found that the Department of Labor’s (DOL) 2018 association health plan (AHP)...more
On Friday, March 28, 2019, U.S. District Judge John D. Bates rejected the Trump Administration’s proposal for association health plans (AHP). ...more
This is the one hundred and nineteenth issue in our series of alerts for employers on selected topics on health care reform. ...more
A recent ruling by the United States District Court for the District of Columbia calls into question the recently expanded regulations allowing small employers to band together to establish Association Health Plans....more
On March 28, 2019, the U.S. District Court for the District of Columbia struck down key parts of the U.S. Department of Labor’s (DOL) final rule expanding the availability of association health plans (AHPs). In State of New...more
A federal court struck down key portions of the new association health plan (AHP) regulations last week, just days before the fledgling rules for self-insured medical plans were slated to go into effect regarding...more
The U.S. District Court for the District of Columbia has set aside the most significant portions of the U.S. Department of Labor's (DOL) regulations on Association Health Plans (AHPs)....more
In the last post in this series, we examined the regulatory response by certain states to the final regulations governing association health plans, which were issued by the U.S. Department of Labor (DOL) in June 2018. As we...more
Last year, the President issued an Executive Order directing the Secretary of the Department of Labor (DOL) to issue regulations to expand access to association health plans (AHPs). Earlier this year, the DOL issued final...more
In a summary of the recently issued Association Health Plan (AHP) final regulations, the U.S. Department of Labor (DOL) rightly observed that AHPs are a species of multi-employer welfare arrangements, or MEWAs, that are...more
This is the third article in our series on Association Health Plans (AHP). This week’s discussion focuses on the mixed reaction to the recent Department of Labor (DOL) AHP. In the health benefits market, some state-based...more
New guidance helps plan sponsors and employers manage and operate AHPs - The Department of Labor (DOL) and Internal Revenue Service (IRS) recently released guidance related to the DOL's June 28th final rule on association...more
Department of Labor Issues Final Rule that Expands Association Health Plans - On June 21, 2018, the Employee Benefits Security Administration, Department of Labor (“DOL”) issued a final rule that establishes additional...more
It sure seems like a long, long time since ACA foes were suing to block executive actions to “fix” problems that Congress couldn’t or wouldn’t. Now, it’s the turn of ACA defenders, who are suing to block executive actions to...more
As we advised was likely during our June 29, 2019 webinar, Association Health Plans—Are They Really an Option to Consider?, at least two states were likely to challenge the enforceability of the new regulations issued by the...more
This is the first post in a blog series exploring the U.S. Department of Labor’s recently issued final regulation governing Association Health Plans (AHPs). While AHPs can be either fully-insured or self-funded, the final...more
On October 12, 2017, President Trump signed a “Presidential Executive Order Promoting Healthcare Choice and Competition Across the United States” (the “Executive Order”) to “facilitate the purchase of insurance across state...more