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High Deductible Health Plan First Dollar Coverages in Flux

A recent string of lawsuits, regulatory guidance, and market trends have dramatically impacted the types of services that enjoy first dollar coverage under high deductible health plan (HDHP) and health savings account (HSA)...more

Air Ambulance Cost Reporting Delayed Until Rules are Finalized

The Consolidated Appropriations Act, 2021 requires group health plans to report specific air ambulance claim data, as summarized in our prior articles available here and here. As noted in our prior articles, proposed rules...more

Health Plans’ Gag Clause Attestations Due December 31, 2023

Under the Consolidated Appropriations Act, 2021 (CAA), group health plans and health insurance issuers are required to annually attest that they are in compliance with the CAA’s gag clause prohibition. On a high level, the...more

RxDC Reporting Relief for Plans, Issuers, and Plan Service Providers

On December 23, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) provided welcome relief in the form of an FAQ regarding the Prescription Drug Data Collection (RxDC)...more

Several New Group Health Plan Reporting Deadlines Are Approaching – Check Out Our CAA/Price Transparency Checklist

This year, Foley’s Health Benefits Practice has released multiple alerts on several of the new group health plan requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage...more

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