K&L Gates Triage: An Insider’s Perspective on the Health Care Debate in Washington, DC
On April 29, 2024, the Department of Labor (“DOL”) released a final regulation (the “Final Rule”) that rescinded the Trump Administration rule that expanded the availability of association health plans (“AHPs”) (“Trump DOL...more
The Department of Labor (“DOL”) issued final regulations in June 2018, which loosened the DOL’s long-standing sub-regulatory guidance and allowed more organizations to form Association Health Plans (“AHPs”). ...more
On May 13, 2019, the Department of Labor released additional guidance addressing questions about the enforcement relief announced earlier by the Department pending its appeal of the district court’s ruling that invalidated...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
Last week, the Department of Labor (DOL) responded to the district court decision striking down the final regulations expanding the ability for a group of unrelated employers to form an organization in order to offer health...more
Medical coverage for employees is often a stressful decision for small and family-owned businesses. Providing competitive benefits to employees can help attract and retain good employees....more
On April 26, 2019, the Department of Labor filed a notice of appeal in the case that invalidated key provisions of its Association Health Plan (AHP) regulations. Released last summer, the AHP regulations loosened the...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
On March 28, 2019, in State of New York v. United States Department of Labor, a federal district court in the District of Columbia set aside key portions of the Department of Labor’s final rule (the “Final Rule”) which paves...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
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
The Affordable Care Act returned to the front page this weekend when a federal district court in Texas issued an opinion striking down the entire law as unconstitutional. ...more
On December 14, 2018, a Texas federal court declared the entire Affordable Care Act (ACA) unconstitutional. Despite this broad holding (and clickbait headlines), employers should not expect to see any significant changes to...more
The U.S. Departments of the Treasury, Labor, and Health and Human Services have jointly issued proposed regulations that envision a broad landscape for the use of health reimbursement arrangements (HRAs) and certain other...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
Use of Forfeitures for Safe Harbor Contributions, QNECS and QMACS - The Internal Revenue Service (IRS) recently issued final regulations allowing forfeitures in 401(k) plans to be used to fund safe harbor contributions,...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
The U.S. Department of Labor (DOL) has published a Final Rule that aims to remove restrictions on the establishment of Association Health Plans (AHPs) in order to make affordable health care coverage more accessible to small...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
As “gig” employment becomes more prevalent, many organizations are seeking to differentiate themselves from other similar companies by offering their contract workers benefits. ...more
In June, the Department of Labor issued a final rule that allowed the expansion of Association Health Plans (AHPs). The final rule revised the definition of who can qualify as an “employer” under ERISA and loosened the...more
On June 19, 2018, the U.S. Department of Labor (DOL) issued its highly anticipated final rule expanding the availability of association health plans (AHPs). This article provides a brief overview of this topic, which may be...more