News & Analysis as of

Interim Final Rules (IFR) Department of Labor (DOL)

King & Spalding

Ten-Year Statute of Limitations for Sanctions Violations Update

King & Spalding on

As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more

Groom Law Group, Chartered

Expanded Abandoned Plan Program Gives Certain Bankruptcy Trustees QTA Eligibility, Adopts Other Technical Changes

On May 17, 2024, the Department of Labor (“DOL”) published interim final rules (collectively, the “IFR”) to amend DOL’s 2006 regulations establishing the abandoned plan program, as well as the accompanying prohibited...more

ArentFox Schiff

Mental Health Parity Act: Biden Administration Issues Long-Awaited Rulemaking Cracking Down on Treatment Limitations

ArentFox Schiff on

On July 25, 2023, the US Departments of Labor (DOL), Treasury (DOT), and Health and Human Services (HHS) (the Departments) released a much-anticipated interim final rule to ensure that group health plans comply with the...more

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

Beltway Buzz - July 2023 #4

Su Slips. Acting Secretary of Labor Julie Su’s chances of becoming the actual secretary of labor continued to dwindle this week. Multiple media reports indicate that the administration is no longer pushing for Su’s...more

Foley Hoag LLP

OSHA Announces Interim Final Rule on Antitrust Whistleblower Retaliation Claims

Foley Hoag LLP on

The Occupational Safety and Health Administration (“OSHA”) of the U.S. Department of Labor has released a new rule that will give antitrust whistleblowers added protection against retaliation. The new rule establishes...more

Foley & Lardner LLP

RxDC Reporting Relief for Plans, Issuers, and Plan Service Providers

Foley & Lardner LLP on

On December 23, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) provided welcome relief in the form of an FAQ regarding the Prescription Drug Data Collection (RxDC)...more

King & Spalding

Texas Medical Association Files Third Challenge to No Surprises Act

King & Spalding on

On November 30, 2022, the Texas Medical Association (TMA) filed a third lawsuit challenging the regulations implementing the No Surprises Act (NSA). TMA’s latest suit before the United States District Court for the Eastern...more

Proskauer - Health Care Law Brief

The Saga of the No Surprises Act Continues to be … Surprising

We previously noted that the regulations implementing the No Surprises Act (“NSA”) appeared to be inconsistent with the NSA because they seemed to establish the qualifying payment amount (“QPA”) as the appropriate payment...more

Bass, Berry & Sims PLC

No Surprises Act: New Regulations Improve Dispute Resolution Process for Providers

Bass, Berry & Sims PLC on

On August 19, the federal government issued a final rule addressing certain aspects of the No Surprises Act (NSA). The NSA was enacted in December 2020 to protect commercially insured patients from receiving surprise medical...more

Jackson Lewis P.C.

New No Surprises Act Guidance -Frequently Asked Questions Bolster Final Rule

Jackson Lewis P.C. on

The No Surprises Act (Act), which establishes protections for health plan participants from surprise medical billing, was passed in late 2020 as part of the 2021 Consolidated Appropriations Act....more

Husch Blackwell LLP

Eastern District of Texas Invalidates Parts of Implementing the No Surprises Act

Husch Blackwell LLP on

On July 26, 2022, Judge Jeremy Kernodle of the Eastern District of Texas affirmed that certain parts of the Interim Final Rule Part II implementing the No Surprises Act (the Act) were invalid. This ruling is nearly identical...more

Faegre Drinker Biddle & Reath LLP

Federal District Court Invalidates Some Surprise Billing Rules: What It Means for the No Surprises Act

On February 23, 2022, the United States District Court for the Eastern District of Texas invalidated portions of Part II of the interim final rule (“IFR”) issued by the U.S. Departments of Health and Human Services, Labor,...more

Williams Mullen

New Lifetime Income Illustrations Required This Year

Williams Mullen on

The Setting Every Community Up for Retirement Act (the “SECURE Act”), passed at the end of 2019, adds a participant disclosure requirement that addresses a long-held concern of lawmakers that many participants are not...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

Moore & Van Allen PLLC

Health Care Client Update: No Surprises Act

Moore & Van Allen PLLC on

On January 1, 2022, two Interim Final Rules (the “Rules”) that implement key aspects of the No Surprises Act (“NSA”) became effective. The first Interim Final Rule was initially issued by the U.S. Departments of Health and...more

McDermott Will & Emery

Telemedicine Providers Take Note – The No Surprises Act Is Effective January 1, 2022

McDermott Will & Emery on

On December 27, 2020, the No Surprises Act was signed into law as part of the Consolidated Appropriations Act, 2021. In July and October 2021, respectively, the Department of Health and Human Services, the Department of...more

Foley & Lardner LLP

New Prescription Drug and Health Care Spending Reporting Requirements from a Carrier and Plan Service Provider Perspective

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Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more

Foley & Lardner LLP

Group Health Plans Subject to New Prescription Drug and Health Care Spending Reporting Requirements

Foley & Lardner LLP on

Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more

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

Making a List, Checking It Twice: Year-End Guidance on Drug Cost Reporting

Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data - but no more time to comply with - daunting prescription drug cost reporting requirements in the...more

Jackson Lewis P.C.

It’s Almost the End of 2021. Do You Know Where Your Healthcare Dollars Go?

Jackson Lewis P.C. on

The CAA Transparency Rules Will Let Plans and Participants Know. The Department of Labor, Health and Human Services, and the IRS (collectively the Departments) recently released the Interim Final Rules with a request for...more

Epstein Becker & Green

#WorkforceWednesday: Employee Privacy and COVID-19, CMS Vaccine Mandate on Hold, Independent Contractor Classification -...

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This week, we look at complying with the rules that require employers to keep employee COVID-19 vaccination and testing information confidential. HIPAA, Employee Privacy Protections, and COVID-19 (see video attached) ...more

Fisher Phillips

Federal Departments Shed Light on Upcoming Health Plan Disclosure Requirements

Fisher Phillips on

A collection of federal agencies recently released guidance to assist group plan health sponsors navigate upcoming disclosure obligations. On November 17, the Internal Revenue Service, the U.S. Department of Labor, and the...more

King & Spalding

152 Members of Congress Submit Letter Urging Revisions to No Surprises Act Independent Dispute Resolution Process

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On November 5, 2021, 152 members of the U.S. House of Representatives submitted a letter to the Secretaries of the Departments of Health and Human Services, Labor, and the Treasury (the Departments) urging the Departments to...more

Foley & Lardner LLP

Certain Health Care Employers Must Require Vaccinations to Continue to Participate in Medicare/Medicaid

Foley & Lardner LLP on

Earlier this month, on the same day the Department of Labor’s Occupational Safety and Health Administration (OSHA) issued its COVID-19 Vaccination and Testing Emergency Temporary Standard (ETS), the Centers for Medicare &...more

Maynard Nexsen

New IDR Rules Under The No Surprises Act

Maynard Nexsen on

On September 30, 2021, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) released an interim final rule with comment period entitled...more

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