News & Analysis as of

Final Rules Patient Protection and Affordable Care Act (PPACA) Employee Retirement Income Security Act (ERISA)

Seyfarth Shaw LLP

Does Section 1557 Apply to Employer Group Health Plans? (And — Why That Question May Not Even Matter)

Seyfarth Shaw LLP on

Seyfarth Synopsis: Following years of back and forth, new final rules were published by the Department of Health and Human Services (HHS) on May 6, 2024 reinstituting the Department’s interpretation that the prohibition on...more

Snell & Wilmer

Zombie Benefits Part II: Health Reimbursement Arrangements (“HRAs”) Are Back From the Dead

Snell & Wilmer on

As reported in our November 7, 2018 SW Benefits Blog Zombie Benefits – Are Health Reimbursement Arrangements (“HRAs”) Back From the Dead?, the Departments of Health and Human Services, Labor, and Treasury (the “Agencies”)...more

McDermott Will & Emery

A New Day for the HRA

McDermott Will & Emery on

The Departments of Labor, Treasury, and Health and Human Services have released final rules removing the prohibition on pairing HRAs with individual health policies. The final rules also allow certain HRAs and other...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

Proskauer Rose LLP

ERISA Newsletter - Second Quarter 2019

Proskauer Rose LLP on

Editor's Overview - As the summer heats up, so too has the U.S. Supreme Court's docket for next term where it has already agreed to hear three ERISA cases and more may be in the works. On the docket already are ERISA...more

Jackson Walker

New Tool to Contain Employer Healthcare Costs

Jackson Walker on

Healthcare coverage became an employer-offered benefit during World War II as the result of the federal government’s wage and price controls. Since that time, Medicare has become an important part of how healthcare is...more

Burr & Forman

What the HRA is going on with HRAs?

Burr & Forman on

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

Mintz - Employment Viewpoints

Agencies Issue Final Regulations Expanding Access to Health Reimbursement Arrangements

On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more

Laner Muchin, Ltd.

Federal Agencies Issue Final Regulations Expanding Availability Of HRAs

Laner Muchin, Ltd. on

On June 13, 2019, the Departments of Treasury, Labor, and Health and Human Services issued final regulations, effective January 1, 2020, that allow an employer to reimburse employee premiums for individual health insurance...more

King & Spalding

Compensation and Benefits Insights – May 2019

King & Spalding on

In State of New York v. United States Department of Labor, the District Court for the District of Columbia held that the U.S. Department of Labor’s (“DOL”) final regulations on association health plans (“AHPs”) issued on June...more

Burr & Forman

DOL Provides Transitional Relief to Association Health Plans

Burr & Forman on

On April 29, 2019, the United States Department of Labor (the “DOL”) released a policy statement providing transitional relief from the potential adverse consequences arising from a District Court’s vacating portions of the...more

BCLP

Deep Dive: Association Health Plan Considerations following the Court Order Vacating the DOL’s Final Rule

BCLP on

On March 28, 2019, the Federal District Court for the District of Columbia issued an opinion and order vacating key portions of the Department of Labor’s regulation, published in June 2018, which had expanded the definition...more

McDermott Will & Emery

Court Puts Association Health Plans in Limbo

On March 28, a District of Columbia federal court agreed with a New York-led challenge by a group of 11 states and the District of Columbia and found that the Department of Labor’s (DOL) 2018 association health plan (AHP)...more

Mintz - Employment Viewpoints

Association Health Plan Perspectives (Part 3): Handicapping the Legal Challenge by State Attorneys General to the Final U.S....

In the last post in this series, we examined the regulatory response by certain states to the final regulations governing association health plans, which were issued by the U.S. Department of Labor (DOL) in June 2018. As we...more

Foley & Lardner LLP

The Association Health Plan Challenge: The States Initiate Litigation Challenging the Final Rule

Foley & Lardner LLP on

In our blog post of July 10, 2018, we discussed the key elements of the Final Rule issued on June 21, 2018 with respect to Association Health Plans (AHPs). As we noted, the expansion of ERISA’s definition of an employer and...more

Verrill

New Disability Claims Procedures Affect Retirement Plans and Deferred Compensation Plans Too

Verrill on

Much has been written about the Department of Labor’s final rule regarding disability benefit claims procedures (the “Final Rule”), which took effect on April 2, 2018. And by now, most employers – and all disability insurance...more

K&L Gates LLP

Final Rule Changes to the Edges of U.S. Health Insurance Markets

K&L Gates LLP on

Department of Labor Issues Final Rule that Expands Association Health Plans - On June 21, 2018, the Employee Benefits Security Administration, Department of Labor (“DOL”) issued a final rule that establishes additional...more

Mintz - Employment Viewpoints

Association Health Plan Perspectives (Part 1): Determining the Status of an AHP as “Fully-Insured”

This is the first post in a blog series exploring the U.S. Department of Labor’s recently issued final regulation governing Association Health Plans (AHPs). While AHPs can be either fully-insured or self-funded, the final...more

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

DOL Finalizes Expansive Association Health Plan Rule

The U.S. Department of Labor (DOL) recently finalized its much-anticipated rule which expands opportunities for small businesses and certain self-employed individuals to band together to obtain more affordable group health...more

Snell & Wilmer

Association Health Plans – A New Frontier?

Snell & Wilmer on

On June 21, 2018, the Department of Labor published the final association health plan (“AHP”) rule. 83 FR 28912 (June 21, 2018). The final rule is short, just shy of three pages in length (see page 28961 to 29964), and...more

Eversheds Sutherland (US) LLP

MEWAs and AHPs - what you need to know about the Association Health Plan Final Rule

On June 21, 2018, the Department of Labor (DOL) issued final regulations establishing alternative criteria under section 3(5) of the Employee Retirement Income Security Act of 1974 (ERISA) for forming single-employer...more

Faegre Drinker Biddle & Reath LLP

Association Health Plan Final Rule Brings New Coverage Options for Small Businesses and Self-Employed

On June 19, 2018, the Trump administration took the first step in a three-part effort to expand affordable health plan options for consumers when the U.S. Department of Labor (DOL) finalized a proposed rule designed to make...more

Bradley Arant Boult Cummings LLP

DOL Issues Final Regulations on Association Health Plans - Employee Benefits Alert

The Department of Labor (DOL) has issued final regulations and FAQs on association health plans (AHPs). The regulations broaden the definition of an “employer” under the Employee Retirement Income Security Act (ERISA). The...more

Holland & Knight LLP

U.S. Department of Labor Releases Association Health Plan Regulations

Holland & Knight LLP on

• The Federal Register published a final rule promulgated by the U.S. Department of Labor (DOL) regarding association health plans (AHPs). AHPs are group health plans established by groups or associations of employers that...more

Baker Donelson

Trump Administration Releases Regulations to Expand Association Health Plans

Baker Donelson on

On June 19, the Department of Labor (DOL) released a final rule to expand access to association health plans (AHPs), which allow employers to form groups to collectively purchase health coverage for their employees. ...more

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