On January 16, 2023, the Department of Health and Human Services (“HHS”) dropped its appeal of the U.S. District Court for the District of Columbia’s September 29, 2023 decision that vacated a portion of the 2021 Notice of...more
Seyfarth Synopsis: Recently, the Trump Administration issued its proposed Notice of Benefit & Payment Parameter for 2021 regulations....more
HHS recently issued its proposed Notice of Benefit and Payment Parameters (“NBPP”) for the 2021 calendar year. The 2021 Proposed NBPP allows health plans, including self-insured group health plans, to voluntary count the...more
In ACA FAQ Part 40, HHS, IRS and DOL (the "Departments") delayed the implementation of the controversial rule in HHS 2020 Notice of Benefit and Payment Parameters requiring health plans to credit to the out-of-pocket maximum...more
In our last blog past, we discussed the recent rule finalized by Health and Human Services regarding the calculation of the annual cost-sharing limits for health plan participants who receive financial assistance from drug...more
The Department of Health and Human Services (“HHS”) recently finalized a regulation (the “Regulation”) that informs employers how group health plans may account for drug manufacturer coupons for purposes of the Affordable...more
A class action complaint was filed in federal court last week against New Albertson’s, Inc. the operator of the Jewel-Osco grocery chain, alleging failure to deduct manufacturers’ coupons from the tax base on which sales tax...more