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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
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
In 2019, the Department of Labor (DOL) continued its trend of providing limited advance guidance under the Employee Retirement Income Security Act of 1974, as amended (ERISA). By volume, the amount of 2019 guidance...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
In State of New York v. United States Department of Labor, the District Court for the District of Columbia held that the U.S. Department of Labor’s (“DOL”) final regulations on association health plans (“AHPs”) issued on June...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
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
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
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
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
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
As open enrollment approaches for the 2019 calendar year, below are some items employers may want to consider: Wellness program changes – Many employers change their wellness programs during open enrollment. This is a...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
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
In our blog post of July 10, 2018, we discussed the key elements of the Final Rule issued on June 21, 2018 with respect to Association Health Plans (AHPs). As we noted, the expansion of ERISA’s definition of an employer and...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
The U.S. Departments of the Treasury, Labor, and Health and Human Services have jointly issued final rules modifying the definition of short-term, limited-duration insurance (STLDI). STLDI provides health coverage that is...more
This is the second article in our series on Association Health Plans (AHP). This week’s discussion focuses on the potential impact of the Department of Labor’s (DOL) decision to relax some AHP requirements....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