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Holiday Relief for Reporting Requirements

In a new set of Frequently Asked Questions, the U.S. Departments of Labor, Health and Human Services, and the Treasury provide significant relief to health plan sponsors and insurers seeking to report on expenditures for...more

A Watch on Affordability – IRS Adjusts Figure Applicable to Employer Mandate

The Employer Shared Responsibility Provisions (commonly known as the “employer mandate”) under the Affordable Care Act (ACA) require applicable large employers to pay an assessment under the Internal Revenue Code if they fail...more

Back and Forth to the Future: HHS Issues Proposed Rules on Nondiscrimination

Summary - The Department of Health and Human Services (HHS) has issued proposed regulations under the nondiscrimination provisions of Section 1557 of the Affordable Care Act (ACA). The proposed rules restore and augment a...more

Technical Guidance Issued on Transparency in Coverage Regulations

On April 19, 2022, the U.S. Departments of Health and Humans Services, Labor, and Treasury (collectively, the Departments) issued guidance which sets forth two separate safe harbors for group health plans and health insurance...more

More Guidance on Coverage of Over-the-Counter COVID-19 Test Kits

Following up on their earlier guidance the Departments of the Treasury, Labor, and Health and Human Services have issued an additional set of frequently asked questions and answers on the requirement to cover over-the-counter...more

Provider's Claims for COVID-19 Screening Charges Move Forward

Addressing motions to dismiss, a district court in Texas has found that a provider may proceed with its lawsuit to recover the full amount of its charges for COVID-19 diagnostic testing under the FFCRA and CARES Act from an...more

The CAA's New Identification Card Requirements

Summary - To help individuals better understand the costs they will bear for medical care, the Consolidated Appropriations Act (CAA) requires health plan ID cards to include clear information about deductibles and...more

Understanding the New Continuity of Care Rule

Summary - Under a new rule introduced by the Consolidated Appropriations Act, 2021 (CAA), a health plan or insurer must offer an enrollee the opportunity to elect a transitional period of continued care with a provider...more

Health Plan Fiduciaries Must Solicit Information From Brokers and Consultants

Summary - The Consolidated Appropriations Act, 2021 (CAA) requires the disclosure of information to ensure that brokers and certain consultants receive no more than reasonable compensation for their services....more

Understanding the New Health Care Transparency Requirements

Summary - New rules require group health plans and insurers to disclose pricing information in three phases. This is the third briefing in Ballard Spahr’s series on the Consolidated Appropriations Act, 2021 (CAA) and...more

U.S. Department of Health and Human Services Approves Updates to the List of Preventive Items and Services to be Covered Without...

Revisions to preventive care and screening guidelines will require health plans and health insurance policies to provide 100 percent coverage for additional services for women, adolescents, children, and infants, following an...more

Understanding the New 'No Surprises Rules'

Summary - The following is the first publication in our series on the Consolidated Appropriations Act 2021 (CAA) and transparency regulations. It concerns the rules designed to prevent surprise billings. These No Surprises...more

Health Plan Coverage Required for COVID-19 Testing

Summary - Health plans now are required to cover the cost of over-the-counter COVID-19 test kits obtained without a health care provider’s prescription or clinical assessment. The new requirement is addressed in a set of...more

Something to Be Thankful For - IRS Extends Deadline for Distributing ACA Reports

Each year since employers have been required to prepare reports under the employer and individual mandates of the Affordable Care Act, the IRS has extended the deadline for distributing the forms to employees. It appeared as...more

Upcoming Compliance Deadlines for Health and Welfare Plans

Summary - Throughout 2020 and 2021, employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes arising from the COVID-19 pandemic and new health legislation. To...more

Keeping Up With No Surprises

Summary - Two sets of rules were issued last month by federal agencies as part of the No Surprises Act....more

Enforcement Delayed Under the New Health Plan Disclosure Requirements

Summary - Three federal agencies, the Departments of Labor, Health and Human Services, and Treasury, jointly released new FAQs on August 20, 2021, regarding compliance with new health plan disclosure requirements of the...more

ARP: COBRA Premium Assistance

The United States Department of Labor has issued much anticipated guidance and model forms under the COBRA subsidy rules introduced by the American Rescue Plan (ARP). The FAQ guidance and forms clarify some issues that...more

New Stimulus Law Seeks to Strengthen Mental Health Parity Compliance

This alert is the latest in a series from our Employee Benefits and Executive Compensation and Health Care Practice Groups about the most recent federal stimulus bill. We provided an overview of how the law addresses new...more

Supreme Court Finds ERISA Does Not Preempt State Prescription Drug Pricing Law

Summary The U.S. Supreme Court unanimously upheld an Arkansas statute that regulates the price that pharmacy benefit managers (PBMs) pay retail pharmacies for prescription drugs.   ...more

Court Issues Injunction Against Revised ACA Nondiscrimination Rules

The U.S. District Court for the Eastern District of New York blocked federal rules seeking to remove nondiscrimination protections for health care patients. The blocked rules would have removed protections against...more

Short-Term Limited Duration Insurance Rule Upheld

The U.S. Court of Appeals for the District of Columbia Circuit upheld the final regulations issued by the Trump administration that increased the availability of short term, limited duration insurance (STLDI). ...more

CMS Addresses Extended Deadlines for Benefit Plans

The Department of Health and Human Services Centers for Medicare & Medicaid Services (CMS) has followed the guidance, jointly issued by the U.S. Departments of Labor and the Treasury, that extends benefits-related deadlines...more

IRS Provides Flexibility for Employer-Sponsored Health Plans and FSAs in Response to COVID-19 Pandemic

The Internal Revenue Service (IRS) has issued new guidance, Notice 2020-29, in response to the COVID-19 pandemic, providing for temporary flexibility with respect to mid-year elections made during 2020 under Code section 125...more

Health Insurance Exchanges: A $12B Judgment

The U.S. Supreme Court has determined that the federal government must pay over $12 billion to certain health insurers that participated in health insurance exchanges in the first three years that those exchanges were in...more

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