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Wellness Programs Under Scrutiny in EEOC’s New Wearable Devices Guidance

In December 2024, the U.S. Equal Employment Opportunity Commission (“EEOC”) published a fact sheet addressing how federal nondiscrimination laws, such as the Americans with Disabilities Act (“ADA”), may apply to an employer’s...more

Reproductive Health Care: New HIPAA Restrictions & Compliance Checklist

Earlier this year, the Department of Health & Human Services Office of Civil Rights (“HHS”) published a final “HIPAA Privacy Rule to Support Reproductive Health Care Privacy” that imposes new restrictions on disclosure of...more

Circuit Courts Extend Non-Discrimination Protections for Transgender Individuals

On May 13, 2024, the Eleventh Circuit Court of Appeals held that certain federal non-discrimination protections apply to transgender individuals in the group health plan (insured and self-insured) context. In particular, the...more

Open Season for Regulatory Challenges: Supreme Court Overturns Chevron Deference and Expands Opportunities to Attack Federal Rules

On June 28, 2024, in a 6-3 decision, the Supreme Court overturned Chevron v. Natural Resources Defense Council (“Chevron”), the most-cited case in administrative law. Chevron established a framework for how the federal...more

Latest Update to the Ongoing Challenge to the ACA’s Preventive Services Mandate

On June 21, 2024, the United States Court of Appeals for the Fifth Circuit (“Fifth Circuit”) issued its ruling in Braidwood v. Becerra. The court determined that the Affordable Care Act’s (“ACA”) requirement that group...more

Back to the Future: HHS Publishes ACA Section 1557 Nondiscrimination Final Rule Similar to 2016-Era Regulations

On May 6, 2024, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) and the Centers for Medicare and Medicaid Services (“CMS”) published the long-awaited Nondiscrimination in Health Programs...more

HHS Updates Regulations Implementing Section 504 of the Rehabilitation Act

On May 9, 2024, the Biden Administration continued its push to update and modernize federal nondiscrimination protections by publishing revised regulations (the “Final Rule”) that amend the Department of Health and Human...more

2025 Medicare Advantage and Part D Proposed Rule: What’s New for 2025?

In early November, the Centers for Medicare and Medicaid Services (“CMS”) published the contract year 2025 proposed rulemaking (“Proposed Rule”) for Medicare Advantage (“MA”) and Part D sponsors. The Proposed Rule previews...more

California to Potentially Implement a Long-Term Care Payroll Tax

In 2019, California passed a law that created the Long Term Care Insurance Task Force (“Task Force”) to examine how to design and implement a long-term care insurance program. The Task Force recommended a payroll tax to fund...more

Parity or Bust: Tri-Agencies Propose Sweeping Changes to Mental Health Parity Requirements

On July 25, 2023, the Departments of Health and Human Services, Labor and Treasury (“Tri-Agencies”) issued sweeping new guidance on the Mental Health Parity and Addiction Equity Act (“MHPAEA”), including a Proposed Rule, a...more

The End of the COVID-19 Public Health Emergency and National Emergency Are Near – Are You Ready?

The COVID-19 Public Health Emergency (“PHE”) and National Emergency (“NE”) have been in place since early 2020.  In January 2023, President Biden stated his intention for both to end on May 11, 2023.  There have been many...more

Vermont and New Hampshire Employers Take Note: New State Voluntary Paid Family and Medical Leave Programs

This month, Vermont adopted the Vermont Family and Medical Leave Insurance Plan (“Vermont Program”), a voluntary paid family and medical leave program.  The Vermont Program is substantially similar to the New Hampshire...more

Braidwood: A Challenge to the ACA’s Preventive Services Mandate

On September 7, 2022, the District Court for the Northern District of Texas ruled a key component of the Patient Protection and Affordable Care Act’s (“ACA”) preventive services mandate unconstitutional. Braidwood Mgmt. Inc....more

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