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Cutting Out the Middle Man

Arkansas has become the first state in the nation to enact legislation, effective starting in 2026, prohibiting pharmacy benefit managers (PBM’s) from owning or operating actual pharmacies within the state. We take a look at...more

Final Rules Related to the Mental Health Parity and Addiction Equity Act May Drive You Wild

Seyfarth Synopsis: On September 9, 2024, the Departments of the Treasury, Labor, and Health and Human Services (the “Departments”) released highly anticipated Final Rules under the Mental Health Parity and Addiction Equity...more

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

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

Agencies Defer Final Action on Junk Insurance, While Suggesting Caution Against One Last “Binge”

The agencies have finalized a portion of their proposed rules impacting so-called “junk insurance” regarding short-term limited-duration insurance, but deferred finalizing the more significant changes that would have impacted...more

Employers Consider Post-Dobbs Playbook in Dealing with Alabama Ruling on IVF Treatments

Seyfarth Synopsis: Last week, the Alabama Supreme Court ruled that cryogenically frozen embryos are children and are protected from destruction under state law. This is the latest in a series of post-Dobbs judicial rulings...more

Drugmaker Sued for…Overpaying for Drugs? Lawsuit Ushers in Expected Wave of Welfare Fiduciary Litigation

The first complaint was filed in what is expected to be a wave of litigation alleging breach of fiduciary duty in selecting and monitoring welfare plan vendors. While the facts of this particular case may make it somewhat...more

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

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

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

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

Mental Health Parody: In A Cruel Prank, Agencies Respond to Employer Pleas for Guidance with More Stringent Regulations

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

My Insurance Doesn’t Cover That? Agency Guidance on “Junk Insurance”

Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more

OMG! OMB Reviewing Long-Awaited Mental Health Parity Regulations – Public Release Imminent

Seyfarth Synopsis: Employer health plan sponsors, administrators, and insurers have been eagerly awaiting the U.S. Department of Labor’s upcoming guidance on mental health parity.  According to recent reports, newly proposed...more

Who Do I Need to Sue to Get a Decent Cup of Coffee? Jittery Fiduciaries Consider Options as Health Plan Litigation Froths Up

Seyfarth Synopsis: In light of a recent focus on price transparency, claims data, and hidden fees in the health plan world, employer-sponsored health plans have been bringing their fight to the courtroom in an effort to lower...more

FICA Tax Avoidance Wellness Program Viewed Unfavorably by 87,000 New IRS Agents

Seyfarth Synopsis: Just like a bad penny, schemes promising employers ways to reduce their FICA tax burden, and maybe their employees’ income tax burden at the same time, keep popping up with a slightly different burnish on...more

Final Rules Fix Family Glitch

Seyfarth Synopsis: Recently, on October 11, 2022, the Internal Revenue Service (IRS) issued final regulations which finalized changes to affordability of employer coverage for the family members of employees under Internal...more

Businesses Seek to Provide Abortion Travel Benefits in Light of Potential Supreme Court Decision

Seyfarth Synopsis: In light of recent state-level trends, businesses have begun exploring avenues to assist employees in states with restrictive abortion laws with travel to nearby states to receive abortion services. In...more

If You Can Find an At-Home COVID-19 Test, Your Plan Must Now Pay For It

Seyfarth Synopsis: Since March 18, 2020, group health plans have been required to provide benefits for certain items and services related to testing for or diagnosis of COVID-19 during the applicable emergency period - see...more

Guidance Arrives on Long-Awaited Compensation Disclosures for Group Health Plans

Seyfarth Synopsis: Almost a decade after the 408(b)(2) fee disclosure requirements took effect for retirement plan service providers, Congress finally passed legislation addressing compensation disclosure rules for service...more

IRS Releases Extensive Guidance on ARPA COBRA Subsidy

Seyfarth Synopsis: On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”), which requires plan sponsors to provide free COBRA coverage from April 1, 2021 through September 30, 2021, to...more

ARPA COBRA Subsidy: DOL Releases Model Notices, Punts (to IRS?) on Most Open Issues

Seyfarth Synopsis: As discussed in our March 11, 2021 Alert, Congress has made another avenue of health coverage more accessible by fully subsidizing the cost of COBRA coverage from April 1 - September 30, 2021 for...more

Freedom Ain’t Free. COBRA, On the Other Hand…

Seyfarth Synopsis: The latest COVID relief bill, the American Rescue Plan Act (ARPA), provides for a 100% COBRA premium subsidy from April 1, 2021 through September 30, 2021. ARPA, which was signed into law by President...more

Waistbands Aren’t the Only Thing Requiring Flexibility During the Pandemic: IRS Clarifies Guidance on Latest FSA Provisions and...

Seyfarth Synopsis: The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts (for a more detailed description of those changes, check out our alert). ...more

One-Year Expiration of Outbreak Period: Pandemic Rages On, But It’s (Probably) Time to Pay Your COBRA Premiums

Seyfarth Synopsis: As you’ll recall, last Spring, the DOL and IRS issued guidelines providing relief from certain deadlines for employee benefit plans, retroactive to March 1, 2020 (i.e., the beginning of the COVID-19...more

EEOC Wellness Rules Proposed, Water Bottle Enthusiasts Rejoice

Synopsis: For years, employers have struggled to understand what level of incentives in wellness programs might be considered “voluntary” under the Americans with Disabilities Act (ADA). ...more

EEOC’s New ADA Regulations Could Complicate Employer Plans’ Efforts to Offer Incentives for Getting the COVID Vaccine as Part of a...

Seyfarth Synopsis: As COVID-19 vaccines become more readily available in coming months, employers are exploring ways to maximize vaccination rates within their workforce. Some employers are considering making vaccination...more

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