News & Analysis as of

Proposed Rules Department of Labor (DOL) U.S. Treasury

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

Moore & Van Allen PLLC

The AI Executive Order: What’s Happened and What’s Coming Up… 

Last week, the White House issued an update on President Biden’s October 30, 2023 Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (the “AI EO” or “EO”). The update detailed...more

McDermott Will & Emery

The MHPAEA Proposed Rule: Standards of Care and Medical Necessity

Comments submitted in response to the proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) reflect a broad range of perspectives. Our previous MHPAEA content is available here....more

ArentFox Schiff

No More Surprise Medical Bills: Biden Administration Issues New Surprise Billing Rulemaking Proposing Batching and Procedural...

ArentFox Schiff on

*This is the 12th article in a series analyzing the No Surprises Act and its implementation. To view the entire series, click here. A link to the proposed rule is here.  As background, Congress passed the Act to prevent...more

King & Spalding

Back to the Drawing Board: Agencies Propose Changes to No Surprises Act IDR Process Operations

King & Spalding on

On October 27, 2023, the Departments of HHS, Labor, and Treasury and the Office of Personnel Management (the Departments) released a proposed rule updating the payor-provider dispute resolution process under the federal No...more

McDermott+

Departments Propose Broader Batching and IDR Process Changes for Surprise Billing Claims

McDermott+ on

On October 27, 2023, the US Departments of Health and Humans Services, Labor and the Treasury (the Departments), along with the Office of Personnel Management, issued a proposed rule titled Independent Dispute Resolution...more

McDermott+

McDermottPlus Check-Up: October 6, 2023

McDermott+ on

THIS WEEK’S DOSE - Uncharted Territory in the House: The House voted to remove Rep. McCarthy (R-CA) as Speaker of the House, then recessed until at least October 11, when the House is slated to reconvene to elect a new...more

McDermott Will & Emery

HHS, DOL and Treasury Issue a Proposed Rule Increasing Federal IDR Fees

McDermott Will & Emery on

On September 20, 2023, the US Departments of Health and Human Services (HHS), Labor (DOL) and the Treasury (collectively, the departments) issued a proposed rule related to the No Surprises Act’s (NSA’s) federal independent...more

King & Spalding

CMS Proposes 200% Fee Hike to No Surprises Act IDR Fees

King & Spalding on

On September 20, 2023, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) announced the Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee...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

Troutman Pepper

Proposed Mental Health Parity and Addiction Equity Act Rules Clarify Technical Compliance Requirements, But Practical Challenges...

Troutman Pepper on

On July 25, the Departments of Labor, Health and Human Services, and the Treasury (Departments) jointly issued highly anticipated guidance on mental health and substance use disorder benefits. The guidance takes the form of...more

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Seyfarth Shaw LLP

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Bass, Berry & Sims PLC

New Proposed Mental Health Parity Rules Amid Report of Widespread Failure

Bass, Berry & Sims PLC on

On July 25, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the Departments) released new Proposed Rules (Proposed Rules) that clarify certain requirements imposed by the...more

Ballard Spahr LLP

Details Upon Details: Compliance Under MHPAEA’s New Proposed Regulations

Ballard Spahr LLP on

Summary - The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed...more

King & Spalding

HHS, the Department of Labor, and the Department of the Treasury Release Proposed Rules and a Report to Congress regarding Mental...

King & Spalding on

On July 25, 2023, HHS, the Department of Labor, and the Department of the Treasury (the Departments) issued proposed rules (Proposed Rules) and other information regarding health plan and issuer compliance with mental health...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

Ballard Spahr LLP

New Mental Health Parity Guidance Issued

Ballard Spahr LLP on

Summary - On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - July 2023

The July Monthly Minute introduces Part I of our mental health parity update and provides highlights of the newly released proposed rules under the MHPAEA. Part I: New Proposed Rules Addressing Mental Health Parity...more

Ballard Spahr LLP

Comprehending the Non-Comprehensive: Proposed Rules Tackle Non-Traditional Coverage

Ballard Spahr LLP on

The Departments of Labor, Health and Human Services, and the Treasury have published a set of proposed rules that impose new limits on two types of benefits: short-term limited-duration insurance (STLDI) and fixed indemnity...more

Groom Law Group, Chartered

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

McDermott Will & Emery

Proposed Universal Contraceptive Coverage in Response to Roe Reversal

The US Departments of Health and Human Services, Labor and Treasury (the Departments) recently issued a proposed rule (the proposed rule) to eliminate a moral exemption to the Affordable Care Act (ACA) contraceptive mandate...more

Foley & Lardner LLP

Upcoming Deadline Under The No Surprises Act – Air Ambulance Reporting By Group Health Plans and Insurance Issuers

Foley & Lardner LLP on

Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...more

Sheppard Mullin Richter & Hampton LLP

Tri-Agencies Report MHPAEA Compliance Lacking, But Don’t Name and Shame Plans and Issuers . . . Yet

On January 25, the U.S. Department of Labor (DOL), Department of Health and Human Services (HHS), and the Treasury (collectively the Tri-Agencies) published the first annual report on group health plans’ and health insurance...more

Bricker Graydon LLP

First rules implementing surprise medical billing law issued

Bricker Graydon LLP on

On July 1, 2021, the U.S. Departments of Labor, Treasury, and Health and Human Services (HHS) issued the first rules implementing the No Surprises Act, which prohibits health care providers from billing patients more than...more

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