After Congress declined to extend certain relief allowing first-dollar coverage of telehealth services by high-deductible health plans (HDHPs), health plan sponsors may need to make immediate changes to preserve employees’...more
During the COVID-19 crisis, newly-created relief allowed first dollar coverage for telehealth services under a high deductible health plan (HDHP) without ruining health savings account (HSA) eligibility. That relief was...more
We hope you enjoyed the holidays and are settling back in refreshed and recharged for 2025. With a new year comes new rules; please find our thoughts on some of them below....more
On December 21, 2024, President Biden signed into law the American Relief Act, 2025 (2025 Relief Act), which funds the federal government through March 14, 2025, and provides certain disaster relief provisions and other...more
Employers providing health plan coverage through a high-deductible health plan (HDHP) may need to amend their HDHP before year-end to remove first-dollar telehealth coverage. Although prior regulatory relief permitted...more
As we prepare for another change in Administration in the White House, it is crucial for employers and plan sponsors to stay informed and prepared. While much of what lies ahead is speculative, understanding these possible...more
The IRS recently issued Notices 2024-71 and 2024-75, which expand the list of “preventive care” benefits permitted to be provided by a high deductible health plan (HDHP) without a deductible and the list of benefits...more
The IRS has announced the 2025 cost-of-living adjustments for retirement plan and health and welfare benefit plan limitations. The charts below set forth the applicable limitations....more
October 25, 2024 Of Counsel The IRS has recently released its inflation-adjusted contribution limits for certain tax-advantaged welfare accounts. Understanding these new limits will help employers communicate during open...more
Employees increasingly request (and expect) choice in their benefits. The Internal Revenue Service (IRS) recently released Private Letter Ruling 202434006 (PLR), which approved an employer's program allowing employees to...more
On Labor Day fifty years ago, September 2, 1974, President Ford signed the Employee Retirement Income Security Act of 1974 (ERISA) into law. It is a combination of tax and labor law incorporating trust law like fiduciary...more
The IRS released Rev Proc 2024-25, 2024-22 IRB 1333, dated May 9, 2024, which outlines the inflation-adjusted contribution limits for Health Savings Accounts (HSAs) for the year 2025, as determined under Code Section 223....more
The San Francisco Health Care Security Ordinance (HCSO) is a local ordinance that uniquely applies to employers with workers in the City of San Francisco. The HCSO requires employers to make certain health care expenditures...more
On April 25, 2024, the U.S. Department of Labor (DOL) released regulations redefining who is an investment advice fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA) and the Internal Revenue Code...more
The May Monthly Minute highlights litigation wins for plan fiduciaries in a 401(k) fee case and a wilderness therapy exclusion case, and also sets out the 2025 HSA, HDHP, and excepted benefit HRA COLA adjustments....more
Seyfarth Synopsis: The IRS has announced increases to key limits for certain health and welfare benefit programs, including HSA contributions for 2025. The IRS recently released 2025 cost-of-living adjustments applicable to...more
The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2024-25) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and...more
The IRS has announced increased annual limits for retirement and other benefit plans for 2024. While the increases for 2024 are smaller than we’ve seen in prior years, they still may have a significant impact on plans and...more
On October 2, the Virginia Board of Pharmacy posted a general notice indicating that it had voted to rescind the request for applications (RFA) for a Pharmaceutical Processor license in Health Service Area I. The RFA will now...more
Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector. ...more
Employers’ high deductible health plans (HDHPs) can continue to cover COVID-19 testing and treatment without violating the eligibility rules for health savings accounts (HSAs)—but only through 2024—under new Internal Revenue...more
Recently, the Internal Revenue Service (IRS) announced (See Revenue Procedure 2023-23) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and...more
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
The Biden administration originally announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our prior article for more information). Although the...more
Employers, at least for now, may have some relief from some of the Affordable Care Act (ACA) requirements to cover preventive care services without cost sharing under a nationwide injunction issued March 30, 2023, by a...more