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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

DOL Finalizes Rescission of Association Health Plan Rule

On April 29, 2024, the Department of Labor (“DOL”) released a final regulation (the “Final Rule”) that rescinded the Trump Administration rule that expanded the availability of association health plans (“AHPs”) (“Trump DOL...more

Tri-Agencies Finalize Rule on STLDI, but Kick the Can Down the Road on Fixed Indemnity and the Health Plan Tax Exclusion

On March 28, 2024, the Departments of Labor, Treasury, and Health and Human Services (the “Tri-Agencies”) issued final regulations on short-term, limited-duration insurance (“STLDI”), hospital and other fixed indemnity...more

HHS Drops Appeal in Drug Coupon Case

On January 16, 2023, the Department of Health and Human Services (“HHS”) dropped its appeal of the U.S. District Court for the District of Columbia’s September 29, 2023 decision that vacated a portion of the 2021 Notice of...more

Court Ruling Calls Into Question Whether Plans and Issuers Can Exclude Drug Coupons Towards the MOOP

On September 29, 2023, the U.S. District Court for the District of Columbia vacated the 2021 Notice of Benefit and Payment Parameters (“2021 NBPP”) amendments to Affordable Care Act regulations. The amendments permitted (but...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

Tri-Agencies Issue Proposed Rule on Short-Term, Limited-Duration Insurance, Excepted Benefits, and Level-Funded Plans

On July 7, the Departments of Labor, Treasury, and Health and Human Services (the “Tri-Agencies”) published a long-anticipated proposed rule (“Proposed Rule”) that...more

CMS Charts the Future of Medicare Advantage and Part D in 2024

CMS published the Calendar Year (“CY”) 2024 Medicare Advantage (“MA”) Capitation Rates and Part C and Part D Payment Policies (“Rate Announcement“) on March 31 and, five days later, issued the MA and Part D final rule for...more

Biden’s 2024 Budget Includes Familiar Health, Retirement Proposals

On March 9, 2023, President Biden released his budget for Fiscal Year 2024. Similar to proposals in its last budget, the Administration’s new budget proposes a number of major tax increases, including the following:...more

ACA Preventive Service Requirements Partially Vacated

On March 30, 2023, the District Court for the Northern District of Texas issued an opinion and order in Braidwood Mgmt. Inc. v. Becerra that vacates the implementation and enforcement of certain preventive service provisions...more

CAA 2023 Includes HSA Telehealth Relief, MHPAEA, Medicare, and Medicaid Changes

Last week the Senate passed the Continuing Appropriations Act, 2023 (“CAA23”).  The House of Representatives will likely consider the measure today, and President Biden is expected to sign the bipartisan measure into law...more

CMS Proposed Rule Would Leverage Technology and Interoperability to Improve Prior Authorization

On Tuesday, December 13, the Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule (“New Proposed Rule”) to improve the prior authorization process and advance interoperability for Medicare Advantage...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

July 1 Deadline for Transparency Machine-Readable Files Posting Requirement

As a reminder, on Friday July 1, 2022, with respect to plan or policy years beginning on or after January 1, 2022 through July 1, 2022, group health plans (self-funded and insured) and health insurance issuers are required to...more

Tolling of Important Health and Welfare and Retirement Plan Deadlines Extended Again Due To COVID-19

On February 18, 2022, President Biden again formally extended the COVID-19 National Emergency, which was set to expire on March 1, 2022. As explained in detail in our previous alerts, this most recent extension means that...more

Update! Departments Issue More Guidance Addressing Coverage of Over-the-Counter COVID-19 Tests

On December 2, 2021, President Biden announced new actions to combat COVID-19, given the emergence of the new Omicron variant. As part of his nine-point plan, the President included a directive that “the more than 150...more

Illinois Employers: Are You Complying With the Consumer Coverage Disclosure Act?

Illinois recently enacted the Consumer Coverage Disclosure Act (the “CCDA”), which requires that Illinois employers provide a disclosure to employees regarding how the employer’s group health plan compares with the essential...more

Departments Issue Guidance Addressing Coverage of Over-the-Counter COVID-19 Tests

On December 2, 2021, President Biden announced new actions to combat COVID-19, given the emergence of the new Omicron variant. As part of his nine-point plan, the President included a directive that “the more than 150...more

HHS Issues Proposed Rules Implementing the Individual Health Insurance Agent & Broker Fee Disclosure Requirements

As we discussed in our earlier summary, the Consolidated Appropriations Act, 2021, Public Law 116-260 (“CAA”), signed into law by the President on December 27, 2020, imposed new compensation disclosure requirements upon...more

House Budget Reconciliation Text Includes Significant Health, Paid Leave, and Retirement Provisions

On September 15, the House Ways and Means and Energy and Commerce Committees advanced components of the Democrats’ $3.5 trillion budget reconciliation package (“Budget Legislation” or “the Legislation”). The Legislation...more

Surprise! Tri-Agencies Meet Deadline with First Set of Surprise Billing Rules, With More to Come

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more

Mental Health Parity Remains a Priority for Tri-Agency: MHPAEA Compliance in Response to the CAA

The Mental Health Parity and Addiction Equity Act of 2008’s (“MHPAEA”) provisions of the Consolidated Appropriations Act, 2021 (the “CAA”) became effective February 10, 2021 and added a requirement for group health plans and...more

[Webinar] Surprise Billing Law Imposes New Requirements for Plans and Issuers - January 13th, 2:00 pm - 3:30 pm ET

This webinar will include a discussion on the various provisions of the new surprise billing law, how it interacts with current law, expected guidance from the Biden Administration, and implications for health insurance...more

The Supreme Court Narrows ERISA Preemption in Rutledge v. PCMA

In the recently-decided Rutledge v. Pharmaceutical Care Management Association (“PCMA”), the Supreme Court found 8–0 (Justice Barrett did not take part) that ERISA did not preempt an Arkansas state law that established...more

Post-Election 2020: Healthcare Priorities Under a Biden Administration

The dust has settled and the 2020 election has concluded with former Vice President Biden poised to become president. At the same time, Democratic control of the House of Representatives has narrowed to the smallest margin...more

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