A new litigation trend is emerging regarding fiduciaries of health plans and their duties to prudently evaluate fees being charged by pharmacy benefit managers (“PBM”). Two Fortune 50 employers, Johnson & Johnson and Wells...more
Section 9501 of the American Rescue Plan Act of 2021 (“ARPA”) requires employers, multiemployer trustees and insurers (collectively, “plan administrators”) to provide a 100% subsidy for COBRA health care continuation coverage...more
One of the first questions that must be addressed in order to determine whether an individual is eligible for the temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes)...more
The American Rescue Plan Act of 2021 (“ARPA”) includes a temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes) to “assistance eligible individuals” (“AEIs”). This...more
Over the past two years, there has been a steady uptick of class action litigation alledging deficiencies in the notices that employers are required to provide under the Consolidated Omnibus Budget Reconciliation Act of 1985,...more
With the news about the spread of the 2019 novel coronavirus (“COVID-19”) in the U.S. and the world rapidly evolving, group health plan sponsors need to address how the plan will provide virus-related benefits. ...more
3/13/2020
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