Originally published in February 2025, this updated report provides new material on physician practice management (PPM) arrangements, reference-based pricing arrangements, minimum essential coverage (MEC) and MEC+ plans, and...more
4/23/2025
/ Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health Insurance ,
Healthcare Reform ,
ICHRA ,
Insurance Industry ,
Minimum Essential Coverage ,
Regulatory Agenda ,
Small Business
Small employers seeking to offer robust major medical coverage to employees and their dependents face daunting price and transparency hurdles. Employers with 50 or fewer full-time equivalent employees, so-called “small...more
While a physician practice management (PPM) structure allows for compliance with corporate practice of medicine laws and ease of administration, it often creates inadvertent health plan issues that should be navigated...more
2/24/2025
/ Compliance ,
Corporate Governance ,
Employee Benefits ,
Health Insurance ,
Healthcare ,
Healthcare Reform ,
Insurance Industry ,
Medicare ,
Physicians ,
Reporting Requirements ,
Risk Management
Small employers seeking to offer robust major medical coverage to employees and their dependents face daunting price and transparency hurdles. Employers with 50 or fewer full-time equivalent employees, so-called “small...more
2/17/2025
/ Affordable Care Act ,
Association Health Plans ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health Insurance ,
Healthcare ,
Insurance Industry ,
Risk Management ,
Self-Insured Health Plans ,
Small Employers
Under the Affordable Care Act’s (ACA) employer shared responsibility provisions, applicable large employers (ALEs) must either offer minimum essential coverage that is “affordable” and that provides “minimum value” to their...more
The Mental Health Parity and Addiction Equity Act (MHPAEA) generally requires group health plans and health insurance issuers to ensure that financial requirements (such as copays and deductibles), quantitative treatment...more
12/20/2024
/ Benefit Plan Sponsors ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health and Welfare Plans ,
Health Insurance ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Regulatory Agenda
On the issue of gender-affirming care, how would a Harris-Walz administration affect clients in your practice?
Bottom line: A Harris-Walz administration would likely provide health plans and health plan sponsors with...more
10/22/2024
/ Affordable Care Act ,
Donald Trump ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Employment Policies ,
Gender Equity ,
Health Insurance ,
Healthcare ,
Kamala Harris ,
LGBTQ ,
Political Campaigns ,
Political Candidates ,
Presidential Elections ,
Proposed Legislation ,
Proposed Regulation ,
Sex Discrimination ,
Telemedicine
The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated final regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The newly issued...more
9/18/2024
/ Benefit Plan Sponsors ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Health and Welfare Plans ,
Health Insurance ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Popular ,
U.S. Treasury
Recent lawsuits filed against the group health plans of two large US employers underscore the importance of implementing formal welfare benefit plan governance structures that include fiduciary committees comparable to the...more
If our trade and industry sources have it right, we could see final regulations implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), as most recently amended by the Consolidated Appropriations Act, 2021...more
8/6/2024
/ Chevron Deference ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Government Agencies ,
Health and Welfare Plans ,
Loper Bright Enterprises v Raimondo ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
Noncompliance ,
NQTLs ,
Proposed Regulation ,
Regulatory Agenda ,
SCOTUS ,
Statutory Authority ,
U.S. House ,
U.S. Treasury
On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more
7/30/2024
/ Congressional Budget Office ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health Insurance ,
Healthcare ,
Insurance Industry ,
Mental Health ,
MHPAEA ,
NQTLs ,
Proposed Regulation ,
U.S. Treasury
A question in response to last week’s post on self-funding of employer group health plans assumed that stop-loss coverage under a level-funded plan could be provided under a group captive medical captive. However, it cannot...more
In a recent article in Managed Healthcare Executive, Peter Wehrwein examines the trend of self-funding of group health benefits by smaller employers who used to depend mainly or entirely on fully insured programs....more
In a recent On the Subject (available here), we reported on the impact of the final rule (final rule) interpreting Section 1557 of the Affordable Care Act (ACA) on self-funded group health plans that contract with licensed...more
5/21/2024
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Covered Entities ,
Employee Benefits ,
Final Rules ,
Health and Welfare Plans ,
Health Insurance ,
Medicare ,
Medicare Advantage ,
Medicare Modernization Act ,
Medicare Part D ,
Section 1557 ,
Self-Funded Health Plans
The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2024-25) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and...more
5/10/2024
/ Benefit Plan Sponsors ,
Deductibles ,
Employee Benefits ,
Employer Group Health Plans ,
HDHP ,
Health Insurance ,
Health Plan Sponsors ,
Health Savings Accounts ,
HRA ,
HSA ,
IRS
A recently decided US Court of Appeals for the Ninth Circuit case, Ryan S. v. UnitedHealth Group, Inc., offers some useful insights on the enforcement by private litigants of the Mental Health Parity and Addiction Equity Act...more
4/19/2024
/ Appeals ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Liability Issues ,
ERISA Litigation ,
Health and Welfare Plans ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Regulation ,
Proposed Rules
Federal legislative and regulatory activity related to employer-sponsored group health plans shows no signs of slowing, particularly with the issuance of interpretive guidance regarding the transparency and surprise-billing...more
2/26/2024
/ Dobbs v. Jackson Women’s Health Organization ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health Insurance ,
Healthcare ,
Insurance Industry ,
Legislative Agendas ,
Regulatory Agenda ,
SCOTUS ,
Self-Funded Health Plans
This post continues our consideration of comments submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). Our previous MHPAEA content is available...more
2/20/2024
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health and Welfare Plans ,
Health Insurance ,
Healthcare Reform ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
U.S. Treasury
Comments submitted in response to the proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) reflect a broad range of perspectives. Our previous MHPAEA content is available here....more
2/2/2024
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health and Welfare Plans ,
Mental Health ,
Mental Health Initiatives ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Rules ,
Standard of Care ,
U.S. Treasury
After a brief hiatus to discuss the pleading standards adopted by the US Court of Appeals for the Tenth Circuit in E.W. v. Health Net Life Insurance Company, we return to our examination of the comments submitted in response...more
This post continues our focus on comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The proposed regulations were issued earlier this year by the US...more
Employer-sponsored health insurance covers almost 159 million non-elderly US workers and their dependents, and employees and jobseekers alike view group health coverage as the single most important non-cash job-related...more
11/28/2023
/ Affordable Care Act ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employees ,
Employer Group Health Plans ,
Employer Liability Issues ,
Fiduciary Duty ,
Health Insurance ,
Insurance Industry ,
Regulatory Agenda
In our last post, we considered some of the comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and...more
11/14/2023
/ Biden Administration ,
Comment Period ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health and Welfare Plans ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
We continue 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 Departments)...more
11/8/2023
/ Biden Administration ,
Comment Period ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
Insurance Industry ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Regulation
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