News & Analysis as of

Consolidated Appropriations Act (CAA) Reporting Requirements

Verrill

The Gag Clause Quandary for Self-Insured Group Health Plans—New FAQ Guidance

Verrill on

The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

Davis Wright Tremaine LLP

COVID-19 Telehealth Flexibilities Extending and Enduring

In the wake of an end of year filled with intense negotiations and political wrangling, Congress has successfully enacted the American Relief Act, 2025 ("the Budget Bill" or "legislation"), narrowly averting a government...more

Verrill

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

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Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

Woodruff Sawyer

Compliance Alert: Reminder: RxDC Reporting Due June 1st

Woodruff Sawyer on

As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Bradley Arant Boult Cummings LLP

Making the First “Gag Clause” Attestations: A Quick Reference Guide

Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

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Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Proskauer - Employee Benefits & Executive...

Here We Go Again: Prescription Drug Reporting Due by June 1st

“Didn’t we just do this?” might be the first question asked by many health plan sponsors and administrators when gearing up to complete 2022 prescription drug reporting by June 1, 2023.  The answer to that question is both...more

Foley & Lardner LLP

Modernization of Cosmetics Regulation Act of 2022: What You Need to Know

Foley & Lardner LLP on

On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act, 2023, which includes the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). MoCRA significantly changes the current regulatory...more

Stinson - Benefits Notes Blog

Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting

On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are...more

Woodruff Sawyer

Compliance Alert: Agencies Extend RxDC Reporting Deadline to January 31, 2023

Woodruff Sawyer on

On December 23, 2022, federal agencies released ACA and CAA Implementation FAQ Part 56, which extends the December 27, 2022 deadline for Prescription Drug Data Collection Reporting (“RxDC Reporting”) through January 31, 2023,...more

McDermott Will & Emery

Welcome (But Last Minute) Relief for Prescription Drug Reporting Originally Due December 27

McDermott Will & Emery on

Section 204 of Title II of Division BB of the Consolidated Appropriations Act, 2021 amended the Internal Revenue Code, the Employee Retirement Income Security Act of 1974 and the Public Health Service Act to add rules...more

Verrill

A Last-Minute Gift – Prescription Drug Reporting Grace Period and Good Faith Relief

Verrill on

In a move akin to last-minute gift-giving, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) released FAQ 56 on December 23, 2022, which provides relief regarding the Prescription Drug...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Federal Regulators Offer Employer Health Plans Last-Minute Relief on Prescription Drug Reporting

Employers have a reprieve from the challenging December 27, 2022, deadline for reporting 2020 and 2021 prescription drug cost information to the U.S. Department of Health and Human Services (HHS). ...more

Laner Muchin, Ltd.

Reminder: Deadline for Prescription Drug and Certain Medical Claim Reporting is December 27, 2022

Laner Muchin, Ltd. on

The 2021 Consolidated Appropriations Act (CAA) established new transparency requirements for group health plans to report specific information about prescription drugs and health care spending to the Centers of Medicaid and...more

FordHarrison

Deadline for Prescription Drug and Health Care Spending Reporting

FordHarrison on

The Consolidated Appropriations Act (CAA) adopted a new prescription drug reporting mandate on November 12, 2021. The mandate requires group health plans and group health insurers to submit prescription drug and health care...more

Holland & Hart - The Benefits Dial

I Want a New Drug…Prescription Drug Data Collection Reporting is Due December 27th

Plan sponsors are ultimately responsible for compliance with the Prescription Drug Data Collection (RxDC) required reporting for their group health plans—and there’s no time to waste since the reporting is due by December 27,...more

Jackson Lewis P.C.

December 27, 2022, Deadline for Mandatory Rx Data Collection Reporting

Jackson Lewis P.C. on

As group health plan sponsors, employers are responsible for ensuring compliance with the prescription drug data collection (RxDC) reporting requirements added to ERISA by the Consolidated Appropriations Act of 2021 (CAA). ...more

Foley & Lardner LLP

Price Transparency and CAA Checklist for Plan Service Providers

Foley & Lardner LLP on

Group health plans must comply with several new requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage regulations (TiC Regulations) under the Affordable Care Act (ACA). ...more

Paul Hastings LLP

Treasury Issues Final Guidance on Housing Tax Credit Income Averaging Rule; IRS Extends Deadlines

Paul Hastings LLP on

On October 7, 2022, Treasury issued final and temporary regulations on the income averaging rules for the low-income housing tax credit (“LIHTC”) under Section 42 of the U.S. Internal Revenue Code of 1986, as amended (the...more

Foster Garvey PC

New Reporting Requirements for Critical Infrastructure and Businesses

Foster Garvey PC on

The Cyber Incident Reporting for Critical Infrastructure Act of 2022 ("the Act") was signed into law by the President on March 15, 2022, as part of the Consolidated Appropriations Act. The purpose of the Act is to educate...more

Jackson Lewis P.C.

Cyber Incident, Ransom Payment Reporting to DHS Mandatory for Critical Infrastructure Entities

Jackson Lewis P.C. on

Included within the Consolidated Appropriations Act, 2022, signed by President Joe Biden on March 15, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Act) creates new data breach reporting requirements....more

Womble Bond Dickinson

Legislation Requiring Reporting of Certain Cyber Incidents Enacted

Womble Bond Dickinson on

President Biden has signed into law the Consolidated Appropriations Act of 2022 (2022 CAA), which includes the Cyber Incident Reporting for Critical Infrastructure Act (Cyber Incident Reporting Act). The Cyber Incident...more

Perkins Coie

Contractual Considerations for Self-Funded Group Health Plan Sponsors in 2022

Perkins Coie on

In our January 2022 update, we discussed new federal requirements that group health plans should pay close attention to in 2022. The sponsor of a self-funded plan will need to work closely with its legal counsel, benefits...more

Holland & Hart - The Benefits Dial

What Happens in a Small Town Stays in a Small Town … Until the DOL Doubles Down on Mental Health Parity Compliance

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued their joint report to Congress regarding their Mental Health...more

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