Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more
In light of the March 30 Braidwood Mgmt. Inc. v. Becerra decision, the Department of Labor, Department of Health and Human Services, and Department of the Treasury (the “departments”) have issued FAQ guidance on how the...more
4/21/2023
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Employer Liability Issues ,
Health Insurance ,
New Guidance ,
Preventive Health Care ,
U.S. Treasury ,
Wellness Programs
With the COVID-19 Public Health Emergency (PHE) set to end on May 11, 2023, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the “departments”) have published FAQs explaining...more
4/14/2023
/ Children's Health Insurance Program (CHIP) ,
COBRA ,
Coronavirus/COVID-19 ,
Deadlines ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Executive Compensation ,
Medicaid ,
Public Health Emergency ,
U.S. Treasury ,
Vaccinations ,
Virus Testing
A federal judge has struck down a provision of the Affordable Care Act (ACA) mandating group health plans and insurers to cover a long list of preventive services without cost-sharing from participants. The March 30 decision...more
The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more
11/24/2021
/ Affordable Care Act ,
Corporate Counsel ,
Deadlines ,
Employee Benefits ,
Employees ,
Employer Group Health Plans ,
Employer Liability Issues ,
Extensions ,
Good Faith ,
Health Insurance ,
IRS ,
Proposed Regulation ,
Reporting Requirements
In Notice 2021-31, the Internal Revenue Service (IRS) provides broad guidance in a question-and-answer format on the application of the American Rescue Plan Act of 2021 (ARP) regarding premium assistance under the...more
6/2/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
COBRA ,
Employee Benefits ,
Employees ,
Employer Group Health Plans ,
Employer Liability Issues ,
IRS ,
Notice Requirements ,
Premium Subsidies ,
Termination Clauses
Group health plans and insurers have been required since 2008 to ensure that any “nonquantitative treatment limitations” (NQTLs) imposed on mental health or substance use disorder (MH/SUD) benefits are comparable and no more...more
5/19/2021
/ Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
IRS ,
Mental Health ,
Noncompliance ,
NQTLs ,
State Legislatures ,
State Regulators ,
Substance Abuse
As we discussed in a previous article, the American Rescue Plan Act of 2021 (ARP), provided premium assistance and an extended election period under COBRA and similar state laws for “assistance eligible individuals” (AEIs)....more
In Notice 2021-15, the IRS provides many answers to questions regarding the temporary special rules introduced as part of the Consolidated Appropriations Act, 2021 (CAA) for health flexible spending accounts (health FSAs) and...more
3/2/2021
/ Cafeteria Plans ,
Carry-Over Basis ,
COBRA ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Dependent Care Assistance Program (DCAP) ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Flexible Spending Accounts ,
Grace Period ,
IRS
The recently enacted COVID-19 Related Tax Relief Act of 2020 and the Taxpayer Certainty and Disaster Tax Relief Act of 2020, both of which are part of the “Consolidated Appropriations Act, 2021,” includes the following...more
1/4/2021
/ Benefit Plan Sponsors ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
IRS ,
New Legislation ,
Relief Measures ,
Retirement Plan ,
Trump Administration
The president has signed into law the Taxpayer Certainty and Disaster Tax Relief Act of 2020, which includes several temporary special rules aimed at minimizing forfeitures and increasing the utility of health and dependent...more
12/30/2020
/ Carryover Basis ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Employees ,
Employer Group Health Plans ,
Employer Liability Issues ,
Flexible Spending Accounts ,
IRS ,
Relief Measures ,
Temporary Regulations ,
Trump Administration
The Departments of Labor (DOL), Health and Human Services (HHS), and Treasury have issued a proposed rule for grandfathered group health plans under the Affordable Care Act (ACA). The proposed rule provides greater...more
The President recently signed into law the Coronavirus Aid, Relief, and Economic Security Act or “CARES Act.” The CARES Act is primarily a stimulus package that addresses the current coronavirus crisis, and it includes...more
The nation’s lawmakers, government agencies, and insurance carriers are taking measures to remove financial barriers to testing and treatment for the novel coronavirus disease (COVID-19). Employers sponsoring health plans...more
3/19/2020
/ Coronavirus/COVID-19 ,
Cost-Sharing ,
Employee Benefits ,
Employer Group Health Plans ,
HDHPs ,
Health Insurance ,
Health Savings Accounts ,
HSA ,
IRS ,
State and Local Government ,
Virus Testing
The Internal Revenue Service originally announced in 2017 that the 2018 contribution limit for health savings accounts (HSAs) corresponding to family coverage under a high-deductible health plan would be $6,900. Then, in...more
The IRS previously announced that the 2018 contribution limit for health savings accounts (HSAs) corresponding to family coverage under a high-deductible health plan would be $6,900. However, now three months into 2018, the...more