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Epstein Becker & Green

Mental Health Parity: Federal Departments of Labor, Treasury, and Health Release Landmark Regulations

Epstein Becker & Green on

On September 9, 2024, the three federal departments responsible for regulating the health care benefits for more than 175 million Americans with private health insurance issued a final rule (the “Final Rule”) implementing...more

Seyfarth Shaw LLP

Agencies Release Final Mental Health Parity Rule

Seyfarth Shaw LLP on

On Monday, September 9, 2024, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued their final rule regarding the nonquantitative treatment limitation (NQTL) comparative analysis...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

ACA-Required Coverage of Contraceptive Care Remains Agency Focus

Once again, the U.S. Departments of Labor, Health and Human Services, and the Treasury have issued guidance on the Affordable Care Act’s (ACA) required coverage of contraception without cost sharing, clarifying the permitted...more

Proskauer - Employee Benefits & Executive...

Agencies Update Guidance on Group Health Plan Contraceptive Coverage Requirements

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently issued guidance for group health plans outlining a “therapeutic equivalence” medical management technique for required preventive...more

Faegre Drinker Biddle & Reath LLP

Reminder: Gag Clause Attestations Due by Year-End

The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more

McDermott Will & Emery

The Proposed MHPAEA Regulations’ ‘Meaning of Terms’ Part One: Benefits

McDermott Will & Emery on

This post continues our investigation of proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and Human Services and the Treasury (the...more

Foley & Lardner LLP

Action Steps Health Plans Should Take Now In Response To New DOL Guidance on Mental Health Parity

Foley & Lardner LLP on

The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...more

McDermott+

Special Report - No Surprises Act Update: The TMA III Decision - August 2023

McDermott+ on

The Texas Medical Association and additional plaintiffs have brought four Administrative Procedure Act (APA) challenges to the rules and guidance implementing the No Surprises Act (NSA) (termed TMA I, II, III and IV). The...more

Alston & Bird

Agencies Issue Extensive MHPAEA Guidance: Plan and Issuer Action Required

Alston & Bird on

Our Employee Benefits & Executive Compensation Group summarizes the key provisions of a proposed rule that would impose new Mental Health Parity and Addiction Equity Act requirements on group health plans and health insurance...more

McDermott Will & Emery

The ‘No More Restrictive’ Requirement for NQTLs Under the Proposed MHPAEA Regulations

McDermott Will & Emery on

We previously reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). If adopted in final form, these regulations would vastly complicate compliance by group health plans and health...more

Verrill

DOL Continues Enforcement of Non-Quantitative Treatment Limitation Requirements

Verrill on

Fifteen months ago, we wrote that the U.S. Department of Labor (“DOL”) had informed Congress that it intended to devote substantial resources to enforcing the new comparative analysis requirement for non-quantitative...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Proposed Rules Push Mental Health Parity Up Benefit Priority List

Now you know. It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more

McDermott Will & Emery

Treasury, DOL and HHS Issue Landmark Mental Health Parity Proposed Rule

The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) to better...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Mental Health Parity Compliance Remains a Key Focus for Federal Agencies

On July 25, 2023, the U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of the Treasury released their annual report to the U.S. Congress regarding group health...more

McDermott+

Biden Administration Issues Proposed Reg to Clarify and Enforce Mental Health Parity Requirements

McDermott+ on

Another week, a lot more regs! Last week, the US Departments of Health and Human Services, Treasury and Labor (the Departments) released a proposed reg related to mental health parity requirements for health plans. This week,...more

Manatt, Phelps & Phillips, LLP

First Look at Proposed New Federal Mental Health Parity Rules

Last week, the departments of the Treasury, Labor and Health and Human Services (collectively, the Departments) published long-awaited proposed regulations intended to clarify and improve compliance with the federal mental...more

Foley & Lardner LLP

High Deductible Health Plan First Dollar Coverages in Flux

Foley & Lardner LLP on

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

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

Ballard Spahr LLP on

Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more

Snell & Wilmer

Five Facts About the Annual Gag Clause Prohibition Compliance Attestation

Snell & Wilmer on

Effective December 27, 2020, the Consolidated Appropriations Act, 2021 (“CAA”), as part of its transparency in health care protections, prohibits group health plans and issuers from entering into agreements that directly or...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Verrill on

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Husch Blackwell LLP

The End of the COVID Emergency and Its Impact on Group Health Plan Coverage Requirements

Husch Blackwell LLP on

After nearly three years of emergency measures related to COVID-19, the U.S. government acted this spring to officially end the COVID-19 Public Health Emergency and the National Emergency. Accordingly, the Departments of...more

Proskauer - Employee Benefits & Executive...

Preventive Care in a Post-Braidwood World: Agencies Release Guidance on Preventive Services Coverage Requirements

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently released guidance for group health plans on required preventive services coverage. The guidance was issued in response to a...more

Bradley Arant Boult Cummings LLP

Departments Issue Guidance on Preventive Services under the ACA Following the Braidwood Decision

In light of the March 30 Braidwood Mgmt. Inc. v. Becerra decision, the Department of Labor, Department of Health and Human Services, and Department of the Treasury (the “departments”) have issued FAQ guidance on how the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

No Change in DOL/Treasury Guidance for Employer Health Plans Issued Before Declared End of COVID-19 National Emergency

What does the April 10, 2023, early end of the COVID-19 National Emergency declaration mean for employer health plans? Well, nothing, actually....more

McDermott Will & Emery

Tri-Agencies Address Preventive Services Coverage in the Wake of Braidwood

McDermott Will & Emery on

In response to Braidwood Mgmt. Inc. v. Becerra, a recent case striking down part of the Affordable Care Act (ACA) preventive services mandate, the US Departments of Labor, Health and Human Services, and the Treasury...more

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