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The Gag Clause Quandary for Self-Insured Group Health Plans—New FAQ Guidance

The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

COVID-19 Extension Guidance Makes the Interplay Between COBRA and Medicare (a Bit) Trickier

The rules concerning the interplay between COBRA and Medicare are a frequent source of confusion for employers. The spike in retirements, layoffs, and furloughs attributable to the coronavirus pandemic has produced an...more

High-deductible health plans can cover coronavirus costs

Recognizing the need to eliminate potential administrative and financial barriers to testing for and treatment of the 2019 Novel Coronavirus (COVID-19), in Notice 2020-15, posted today on IRS.gov, the IRS advised that...more

ICHRAs: A Flexible and Predictable Health Care Benefit

On Thursday, January 30, members from Verrill's Employment & Labor group, as well as some from the Employee Benefits & Executive Compensation group, conducted a full-day seminar full of employment law related topics that...more

December 2019 Client Advisory

This Client Advisory highlights important developments in the law governing employee benefit plans and executive compensation over the past year. It offers insight into what these developments mean for employers and plan...more

Near Unity Among the Circuits: Anti-Assignment Provisions are Enforceable

U.S. Courts of Appeals in all but four Circuits have now held that anti-assignment provisions in health insurance plans governed by ERISA are enforceable. In American Orthopaedic & Sports Medicine v. Independence Blue Cross...more

Wellness Programs: Where are we now?

Wellness programs are governed by overlapping and, at times, maddeningly inconsistent regulations and agency guidance. Litigation challenging the wellness program rules issued by the EEOC in 2016 has added another layer of...more

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