News & Analysis as of

Department of Health and Human Services (HHS) Health Reimbursement Account

Faegre Drinker Biddle & Reath LLP

Reminder: Gag Clause Attestations Due by Year-End

The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

Ballard Spahr LLP on

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

Sherman & Howard L.L.C.

Gag Clause Compliance Attestation Requirements for Plan Sponsors

Since 2021, certain group health plans and health insurance issuers have been prohibited from entering into agreements with “gag clauses” (“Gag Clause Prohibition”). By December 31, 2023, these plans and issuers will be...more

Fox Rothschild LLP

The Supreme Court’s Dobbs Ruling Creates a Variety of Significant Legal Issues

Fox Rothschild LLP on

The Supreme Court of the United States held in Dobbs v. Jackson Women’s Health Organization, that the Constitution does not confer a right to abortion, overruling long-standing precedent in Roe v. Wade and Planned Parenthood...more

Foley & Lardner LLP

OIG Issues Report Suggesting Medicare Advantage Companies Perform Chart Reviews and Health Risk Assessments to Drive Higher...

Foley & Lardner LLP on

On September 20, 2021 the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) issued a report suggesting that certain Medicare Advantage (MA) companies were leveraging chart reviews and...more

Seyfarth Shaw LLP

Final Rule regarding Transparency in Coverage for Health Care Services

Seyfarth Shaw LLP on

Seyfarth Comments: The final Transparency in Coverage Rule was published jointly by the Departments of Health and Human Services, Treasury, and Labor on November 12, 2020. The Rule aims to increase transparency in...more

Health Care Compliance Association (HCCA)

OIG report: Payment of $2.6 billion to Medicare Advantage plans raises concerns

Compliance Today (November 2020) - The U.S. Department of Health & Human Services Office of Inspector General (OIG) September 2020 report titled Billions in Estimated Medicare Advantage Payments From Diagnoses Reported...more

Sheppard Mullin Richter & Hampton LLP

HHS OIG Issues Report Critical of Medicare Advantage Risk Adjustment Practices

Earlier this month, the U.S. Department of Health and Human Services Office of the Inspector General (the “OIG”) released a report highlighting concerns about the extent to which Medicare Advantage Organizations (“MAOs”) are...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Texas Insurance Commissioner Issues Bulletin Clarifying Applicability of Texas Small and Large Employer Health Plan Requirements...

On Thursday, February 20, 2020, the Commissioner of the Texas Department of Insurance issued a bulletin clarifying the applicability of Texas’ small and large employer health plan laws and regulations to individual coverage...more

Mintz - Employment Viewpoints

Treasury Department and IRS Proposed Individual Coverage HRA Affordability Safe Harbors

As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more

Fisher Phillips

Health Reimbursement Arrangements: What Employers Need To Know And Avoid

Fisher Phillips on

Health Reimbursement Arrangements (HRAs) are account-based health plans funded with employer contributions to reimburse eligible participants and dependents for medical expenses. Prior to the Affordable Care Act, HRAs were...more

Snell & Wilmer

Zombie Benefits Part II: Health Reimbursement Arrangements (“HRAs”) Are Back From the Dead

Snell & Wilmer on

As reported in our November 7, 2018 SW Benefits Blog Zombie Benefits – Are Health Reimbursement Arrangements (“HRAs”) Back From the Dead?, the Departments of Health and Human Services, Labor, and Treasury (the “Agencies”)...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations Part 4: Excepted Benefit HRAs

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) have expanded the use of health reimbursement arrangements (“HRAs”), including permitting the use of HRAs to...more

McDermott Will & Emery

A New Day for the HRA

McDermott Will & Emery on

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

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

Burr & Forman

What the HRA is going on with HRAs?

Burr & Forman on

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

Mintz - Employment Viewpoints

Agencies Issue Final Regulations Expanding Access to Health Reimbursement Arrangements

On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more

Holland & Knight LLP

New Final Rules Permit Individual Coverage Health Reimbursement Arrangements

Holland & Knight LLP on

• The U.S. Departments of Health and Human Services, Labor and the Treasury (collectively, the Departments) issued Final Rules regarding a new type of health reimbursement arrangement (HRA) – the individual coverage HRA...more

Jackson Lewis P.C.

FYI – New HRA Options In 2020

Jackson Lewis P.C. on

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...

Digging into the New HRA Regulations Part 1 – Individual Coverage HRAs

As discussed in our June 18th blog entry, the Departments of Labor, Health and Human Services, and Treasury (collectively, the “Departments”) recently released final regulations expanding the use of health reimbursement...more

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

Beltway Buzz - June 2019 #3

Board Rules on Union Access. Late last week, the National Labor Relations Board issued a decision involving the balancing of employees’ statutory right to organize with employers’ private property rights. In the case, the...more

Stinson - Benefits Notes Blog

Final HRA Regulations Create New Health Coverage Options For Employers And Employees

On June 13, 2019 the Department of Health and Human Services, Department of Labor and Department of the Treasury released final regulations that create new healthcare coverage options for employers and employees. ...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

White and Williams LLP

Rules Finalized Permitting Employees to Buy Individual Health Insurance Plans through HRAs

White and Williams LLP on

On June 13, 2019, the U.S. Departments of Health and Human Services, Labor and the Treasury issued final rules that will expand the use of health reimbursement arrangements (HRAs), which are a type of account-based health...more

Foley Hoag LLP

New Employee Benefit Rules Expand Health Reimbursement Arrangement Options for Employers

Foley Hoag LLP on

On June 13, 2019, the Internal Revenue Service (IRS), Department of Labor and Department of Health and Human Services (HHS) issued a new regulation that is intended to increase the use of tax-favored health reimbursement...more

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