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Health Insurance Department of Health and Human Services (HHS) Employee Retirement Income Security Act (ERISA)

Hall Benefits Law

Federal Agencies Issue Updated Instructions for Annual Submission of Gag Clause Prohibition Compliance Attestation

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​​​​​​​The U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the Internal Revenue Service (IRS) have updated the Submission Instructions and User Manual for the Gag Clause Prohibition...more

Seyfarth Shaw LLP

Does Section 1557 Apply to Employer Group Health Plans? (And — Why That Question May Not Even Matter)

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Seyfarth Synopsis: Following years of back and forth, new final rules were published by the Department of Health and Human Services (HHS) on May 6, 2024 reinstituting the Department’s interpretation that the prohibition on...more

Manatt, Phelps & Phillips, LLP

[Webinar] Mental Health Parity Update 2024: The Latest Regulatory and Litigation Trends - March 26th, 1:00 pm - 2:00 pm ET

The Mental Health Parity and Addiction Equity Act (MHPAEA) requires health plans and insurers to offer mental health coverage in “parity” with a plan’s medical or surgical coverage. In 2024, as the post-COVID era brings a...more

McDermott Will & Emery

Code § 4980D and Violations of the NQTL Analysis Requirement Under the Proposed MHPAEA Regulations

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This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the...more

Bond Schoeneck & King PLLC

Don’t Choke on the Gag Clause Prohibition Compliance Attestation Requirement of the CAA

On or before Dec. 31, 2023, certain group health plans and health insurance issuers must submit an attestation to the U.S. Department of Health and Human Services (HHS) certifying their compliance with the “gag clause...more

Manatt, Phelps & Phillips, LLP

Wit Redux—Again: Ninth Circuit Again Supersedes Its Prior Opinion in Landmark Mental Health Case

Editor’s Note: In the article below, Manatt discusses the Ninth Circuit’s new opinion in the ongoing Wit v. United Behavioral Health litigation and the changes from the now-vacated January 2023 Wit decision. ...more

Manatt, Phelps & Phillips, LLP

First Look at Proposed New Federal Mental Health Parity Rules

Last week, the departments of the Treasury, Labor and Health and Human Services (collectively, the Departments) published long-awaited proposed regulations intended to clarify and improve compliance with the federal mental...more

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

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Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more

Verrill

Surprise Medical Bills: Texas District Court Vacates Portion of Independent Dispute Resolution (IDR) Process in Agency Rule

Verrill on

The U.S. District Court for the Eastern District of Texas recently vacated a portion of the Requirements Related to Surprise Billing, Part II, Interim Final Rule (the “Rule”) regarding the independent dispute resolution (IDR)...more

Epstein Becker & Green

2022 Mental Health Parity Report to Congress Highlights Increased Enforcement Efforts

On January 25, 2022, the U.S. Department of Labor (“DOL”), Department of Health and Human Services, and Department of the Treasury (collectively, “Departments” or “Regulators”) released their 2022 Annual Report to Congress on...more

Ballard Spahr LLP

The CAA's New Identification Card Requirements

Ballard Spahr LLP on

Summary - To help individuals better understand the costs they will bear for medical care, the Consolidated Appropriations Act (CAA) requires health plan ID cards to include clear information about deductibles and...more

Foley & Lardner LLP

The Consolidated Appropriations Act’s Compensation Disclosure Provisions from a Carrier and Plan Service Provider Perspective

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...The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) sets forth new compensation disclosure requirements that apply to brokers and consultants with respect to both fully-insured and self-insured group health...more

Manatt, Phelps & Phillips, LLP

Health Insurance Broker Compensation Disclosures Coming in 2022

The Consolidated Appropriations Act, 2021 (CAA), made dozens of changes to health care regulation, including a landmark ban on surprise medical billing. Easily overlooked were new compensation disclosure requirements related...more

Groom Law Group, Chartered

HHS Issues Proposed Rules Implementing the Individual Health Insurance Agent & Broker Fee Disclosure Requirements

As we discussed in our earlier summary, the Consolidated Appropriations Act, 2021, Public Law 116-260 (“CAA”), signed into law by the President on December 27, 2020, imposed new compensation disclosure requirements upon...more

Holland & Knight LLP

HHS Issues Interim Final Rule Implementing Certain Provisions of the No Surprises Act

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The U.S. Departments of Health and Human Services (HHS), Labor and Treasury, along with the Office of Personnel Management, on July 1, 2021, issued a much-anticipated Interim Final Rule with Comment Period (IFC) –...more

McGuireWoods Consulting

The Courts and Healthcare Policy - July 2021

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

Faegre Drinker Biddle & Reath LLP

Departments Release FAQs on Implementing the Mental Health and Substance Use Disorder Parity Requirements under the Consolidated...

As described in a recent blog post, the Consolidated Appropriations Act, 2021 amended the Mental Health Parity and Addiction Equity Act (MHPAEA) to require group health plans and health insurance issuers (collectively, “group...more

Locke Lord LLP

DOL, HHS, and Treasury Jointly Issue FAQs on the CAA’s Mental Health and Substance Use Disorder Parity Provisions

Locke Lord LLP on

On April 2, 2021, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued Frequently Asked Questions (“FAQs”) related to the implementation of the mental health and substance use disorder...more

McDermott Will & Emery

A New Day for the HRA

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The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more

Jackson Walker

New Tool to Contain Employer Healthcare Costs

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Healthcare coverage became an employer-offered benefit during World War II as the result of the federal government’s wage and price controls. Since that time, Medicare has become an important part of how healthcare is...more

Jackson Lewis P.C.

FYI – New HRA Options In 2020

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Health Reimbursement Arrangements (HRA) have been around for years and are an outstanding benefit to help employees enrolled in an employer’s group health plan pay for their insurance premiums. What happens though when an...more

Proskauer - Employee Benefits & Executive...

Departments Publish Final Regulations Expanding the Availability of HRAs

On June 13, 2019, the Department of Labor, together with the Department of Health and Human Services and the Department of the Treasury (collectively, the “Departments”), published final regulations designed to expand the use...more

Burr & Forman

DOL Provides Transitional Relief to Association Health Plans

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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

Snell & Wilmer

Zombie Benefits – Are Health Reimbursements Arrangements (“HRAs”) Back From the Dead?

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The Affordable Care Act (“ACA”) has not been kind to health reimbursement arrangements (“HRAs”). Many employers got rid of HRAs, or integrated them with a major medical plan, in order to avoid significant penalties under the...more

Foley & Lardner LLP

Health Care Policy Newsletter - July 2018 pt 2

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Foley & Lardner LLP’s (“Foley”) Bipartisan Public Policy Team is pleased to share our “Public Policy Weekly* Health Care Newsletter” in which we compile the latest Health Care policy news and legislation. *Please note that we...more

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