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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

Agencies Release Final Mental Health Parity Rule

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

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

New Guidance on Gag Clause Attestation

Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may...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

Yes, I Know it’s a Pandemic, But What About ERISA?!?!?!? Benefits Implications in Employer-Sponsored COVID Vaccine Programs

Synopsis: Now that we have two approved vaccines (and several more on the horizon) employers are starting to explore whether they should require their employees to get vaccinated in order to report to work. ...more

Deadline is Approaching for Group Health Plan Service Agreement Updates

Seyfarth Synopsis: Recent changes to the federal rules governing confidentiality of substance use disorder (SUD) patient records may require updates to agreements between group health plans and their third-party vendors....more

Court Directs EEOC to Reconsider Wellness Rules, Leaves Current Rules in Effect

On Tuesday, August 22, the US District Court for the District of Columbia ordered the EEOC to revisit its controversial rules placing certain limits on employer-sponsored wellness programs under the Americans with...more

Issue 108: HHS Moves Ahead In Face of ACA Uncertainty

This is the one hundred and eighth issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of...more

Issue 102: ACA Post-Election Outlook

This is the one hundred and second issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of...more

Issue 98: Year-End Agency FAQs Address Many Unanswered ACA Concerns

This is the ninety-eighth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

Issue 91: Agencies Issue Guidance on Wraparound Coverage and Supplemental Insurance Products as Excepted Benefits

This is the ninety-first issue in our series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis of certain aspects...more

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