The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated final regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The newly issued...more
9/18/2024
/ Benefit Plan Sponsors ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Health and Welfare Plans ,
Health Insurance ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Popular ,
U.S. Treasury
If our trade and industry sources have it right, we could see final regulations implementing the Mental Health Parity and Addiction Equity Act (MHPAEA), as most recently amended by the Consolidated Appropriations Act, 2021...more
8/6/2024
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Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Government Agencies ,
Health and Welfare Plans ,
Loper Bright Enterprises v Raimondo ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
Noncompliance ,
NQTLs ,
Proposed Regulation ,
Regulatory Agenda ,
SCOTUS ,
Statutory Authority ,
U.S. House ,
U.S. Treasury
On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more
7/30/2024
/ Congressional Budget Office ,
Consolidated Appropriations Act (CAA) ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health Insurance ,
Healthcare ,
Insurance Industry ,
Mental Health ,
MHPAEA ,
NQTLs ,
Proposed Regulation ,
U.S. Treasury
This post continues our consideration of comments submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). Our previous MHPAEA content is available...more
2/20/2024
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health and Welfare Plans ,
Health Insurance ,
Healthcare Reform ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
U.S. Treasury
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
2/2/2024
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health and Welfare Plans ,
Mental Health ,
Mental Health Initiatives ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Rules ,
Standard of Care ,
U.S. Treasury
After a brief hiatus to discuss the pleading standards adopted by the US Court of Appeals for the Tenth Circuit in E.W. v. Health Net Life Insurance Company, we return to our examination of the comments submitted in response...more
This post continues our focus on comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The proposed regulations were issued earlier this year by the US...more
In our last post, we considered some of the comment letters submitted in response to proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the US Departments of Labor, Health and...more
11/14/2023
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Comment Period ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Health and Welfare Plans ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Regulation ,
Regulatory Agenda ,
U.S. Treasury
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
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
9/26/2023
/ Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Health and Welfare Plans ,
Health Insurance ,
Healthcare Reform ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
U.S. Treasury
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
9/21/2023
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Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Health Insurance ,
Internal Revenue Code (IRC) ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
PHSA ,
Proposed Regulation ,
U.S. Treasury
In previous posts, we reported on proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) issued by the Departments of Labor, Health and Human Services, and the Treasury (collectively, the...more
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
8/29/2023
/ Affordable Care Act ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Enforcement Actions ,
Health and Welfare Plans ,
Health Insurance ,
Healthcare Reform ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
U.S. Treasury
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
8/4/2023
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Biden Administration ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Employer Liability Issues ,
Mental Health ,
Mental Health Parity Rule ,
MHPAEA ,
NQTLs ,
Proposed Regulation ,
U.S. Treasury
A recent article by the Kaiser Family Foundation (KFF) and National Public Radio (NPR) raised the prospect that patients may still see surprise medical bills despite the enactment of the No Surprises Act (NSA)....more
7/25/2023
/ Affordable Care Act ,
Billing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
No Surprises Act (NSA) ,
Out of Network Provider ,
Surprise Medical Bills ,
U.S. Treasury
Recently issued Notice 2023-43 provides interim guidance on certain changes to the Employee Plans Compliance Resolution System (EPCRS) made by the SECURE 2.0 Act of 2022. In particular, the notice addresses how plan sponsors...more
The Biden administration previously 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 series introduction for more information). On April...more
5/17/2023
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Biden Administration ,
COBRA ,
Coronavirus/COVID-19 ,
Deadlines ,
Deductibles ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
EBSA ,
Employee Benefits ,
Employer Liability Issues ,
Health Insurance ,
Public Health Emergency ,
U.S. Treasury
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
5/2/2023
/ Biden Administration ,
Coronavirus/COVID-19 ,
Deductibles ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Liability Issues ,
Health Insurance ,
HSA ,
Public Health Emergency ,
U.S. Treasury ,
Vaccinations
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
4/18/2023
/ Affordable Care Act ,
Appeals ,
Contraceptive Coverage Mandate ,
Cost-Sharing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Health Insurance ,
Motion To Stay ,
Preventive Health Care ,
Religious Exemption ,
U.S. Treasury
The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information)....more
4/4/2023
/ Benefit Plan Sponsors ,
Biden Administration ,
COBRA ,
Coronavirus/COVID-19 ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Employees ,
Employer Group Health Plans ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
HSA ,
Public Health Emergency ,
U.S. Treasury ,
Vaccinations ,
Virus Testing
The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). A key...more
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
2/9/2023
/ Affordable Care Act ,
Burwell v Hobby Lobby ,
Contraceptives ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dobbs v. Jackson Women’s Health Organization ,
Employer Group Health Plans ,
Proposed Rules ,
Religious Freedom Restoration Act (RFRA) ,
Reproductive Healthcare Issues ,
Roe v Wade ,
SCOTUS ,
U.S. Treasury
Section 204 of Title II of Division BB of the Consolidated Appropriations Act, 2021 amended the Internal Revenue Code, the Employee Retirement Income Security Act of 1974 and the Public Health Service Act to add rules...more