We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA...more
7/28/2025
/ Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Employee Benefits ,
Financial Services Industry ,
FinTech ,
Gramm-Leach-Blilely Act ,
Health Insurance ,
ICHRA ,
Lenders ,
Money Services Business ,
Payment Systems ,
Regulatory Requirements
President Trump signed into law the One Big Beautiful Bill Act (OBBB) on July 4, 2025. The telehealth safe harbor, which allowed first dollar coverage of telehealth services without impacting Health Savings Account (HSA)...more
7/9/2025
/ Employee Benefits ,
Employer Group Health Plans ,
Federal Funding ,
HDHP ,
Health Insurance ,
HSA ,
Internal Revenue Code (IRC) ,
New Legislation ,
Tax Reform ,
Telehealth ,
Trump Administration
The Mental Health Parity and Addiction Equity Act (MHPAEA), and its implementing regulations and guidance, prohibits health insurance policies and group health plans that cover mental health and substance use disorder...more
During the COVID-19 crisis, newly-created relief allowed first dollar coverage for telehealth services under a high deductible health plan (HDHP) without ruining health savings account (HSA) eligibility. That relief was...more
There are new regulations requiring employers who offer hospital indemnity or other fixed indemnity insurance benefits for plan years starting on or after January 1, 2025, to provide specific notice of the benefit to all...more
Individual Coverage Health Reimbursement Arrangements (ICHRAs) have continued to grow in popularity since their inception in 2019 (see our article here summarizing the 2019 rule establishing ICHRAs). While initially it seemed...more
6/19/2024
/ COBRA ,
Employee Benefits ,
Health Insurance Portability and Accountability Act (HIPAA) ,
ICHRA ,
IRS ,
Medicare ,
Payment Systems ,
PCORI ,
Popular ,
Reporting Requirements ,
Small Business ,
Vendors
On January 30th, President Biden announced his intention to end both the COVID-19 national emergency and the COVID-19 public health emergency (together, the “Emergency Declarations”) effective May 11, 2023. The Emergency...more
The Consolidated Appropriations Act, 2021 (CAA) generally requires group health plan sponsors to request and review fee information from their plan service providers who provide brokerage services or consulting. This fee...more
The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) set forth new compensation disclosure requirements that apply to service providers who provide “brokerage services” or “consulting” to group health plans...more
1/14/2022
/ Compensation ,
Consolidated Appropriations Act (CAA) ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Assistance Programs ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Flexible Savings Accounts (FSAs) ,
HRA ,
Pharmacy Benefit Manager (PBM) ,
Third-Party
Earlier this year, we discussed the lifetime income disclosure requirement that was included in the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). When the disclosure requirement becomes...more
9/17/2020
/ Annuities ,
Compliance Dates ,
Defined Contribution Plans ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Federal Register ,
Interim Final Rules (IFR) ,
Lifetime Income Disclosures ,
Retirement Plan ,
SECURE Act
Hundreds of articles have been published about the Setting Every Community Up for Retirement Enhancement, or SECURE, Act, which was signed into law on Dec. 20, 2019, as part of the late budget bill referred to as the Further...more
Hundreds of articles have been published over the last two weeks about the SECURE Act (“Act”), which was signed into law in late December as part of the most recent budget bill. As you are certainly aware by now, the Act...more
1/24/2020
/ 401k ,
403(b) Plans ,
Automatic Enrollment ,
Beneficiaries ,
Benefit Plan Sponsors ,
Compensation & Benefits ,
Defined Contribution Plans ,
Early Retirement Distributions ,
Employee Benefits ,
Individual Retirement Account (IRA) ,
Internal Revenue Code (IRC) ,
New Rules ,
Part-Time Employees ,
Required Minimum Distributions ,
Retirement ,
Retirement Plan ,
Safe Harbors ,
SECURE Act ,
Tax Planning