As summarized in our prior article on this topic, individual coverage health reimbursement arrangements (ICHRAs) are gaining popularity and constituting a larger part of the overall employer-provided health coverage market. ...more
12/19/2024
/ Centers for Medicare & Medicaid Services (CMS) ,
Data Breach ,
Due Diligence ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement ,
FinTech ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HIPAA Privacy Rule ,
HIPAA Security Rule ,
Independent Contractors ,
Medicare Part D ,
Payroll Deductions ,
Third-Party ,
Third-Party Service Provider
There are new regulations requiring employers who offer hospital indemnity or other fixed indemnity insurance benefits for plan years starting on or after January 1, 2025, to provide specific notice of the benefit to all...more
Individual Coverage Health Reimbursement Arrangements (ICHRAs) have continued to grow in popularity since their inception in 2019 (see our article here summarizing the 2019 rule establishing ICHRAs). While initially it seemed...more
6/19/2024
/ COBRA ,
Employee Benefits ,
Health Insurance Portability and Accountability Act (HIPAA) ,
ICHRA ,
IRS ,
Medicare ,
Payment Systems ,
PCORI ,
Popular ,
Reporting Requirements ,
Small Business ,
Vendors
When it comes to employee compensation, companies constantly explore innovative ways to align their workforce’s interests with the organization’s success. One strategy gaining traction is the extension of loans to employees...more
A recent string of lawsuits, regulatory guidance, and market trends have dramatically impacted the types of services that enjoy first dollar coverage under high deductible health plan (HDHP) and health savings account (HSA)...more
7/21/2023
/ Affordable Care Act ,
Benefit Plan Sponsors ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
HDHP ,
Health Care Providers ,
Health Insurance ,
Health Savings Accounts ,
Preventive Health Care ,
Telehealth ,
U.S. Treasury
The Consolidated Appropriations Act, 2021 requires group health plans to report specific air ambulance claim data, as summarized in our prior articles available here and here. As noted in our prior articles, proposed rules...more
Under the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers are required to annually attest that they are in compliance with the CAA’s gag clause prohibition. On a high level, the...more
On January 30th, President Biden announced his intention to end both the COVID-19 national emergency and the COVID-19 public health emergency (together, the “Emergency Declarations”) effective May 11, 2023. The Emergency...more
The Consolidated Appropriations Act of 2023 (2023 CAA) further extends the HSA safe harbor allowing high deductible health plans (HDHPs) to offer first dollar coverage of telehealth services without ruining HDHP members’...more
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
This year, Foley’s Health Benefits Practice has released multiple alerts on several of the new group health plan requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage...more