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Thorny Laws That ICHRA Vendors Should Consider, Part 2

As summarized in our prior article on this topic, individual coverage health reimbursement arrangements (ICHRAs) are gaining popularity and constituting a larger part of the overall employer-provided health coverage market. ...more

Final Mental Health Parity Rules – Top Five Changes to the Status Quo

The Mental Health Parity and Addiction Equity Act and its implementing regulations and guidance (MHPAEA) prohibit health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD)...more

Key Considerations When Offering Abortion Coverage Under a Group Health Plan

Not surprisingly, leading up to and in the wake of the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, our employee benefits team has been spending a lot of time helping our clients wade through...more

CAA Requires Employers to Request and Review Fee Information from Certain Group Health Plan Service Providers

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

CAA Compensation Disclosures: DOL’s New FAB Confirms the Scope is Broad

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

The Consolidated Appropriations Act’s Compensation Disclosure Provisions from a Carrier and Plan Service Provider Perspective

...The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) sets forth new compensation disclosure requirements that apply to brokers and consultants with respect to both fully-insured and self-insured group health...more

50 State Map of MAC Laws – Can PBMs No Longer Rely on ERISA Preemption to Avoid Certain State Laws?

Recent court trends suggest that preemption under the Employee Retirement Income Security Act (ERISA) may not apply to certain state laws that regulate pharmacy benefit managers (PBMs), including state laws governing Maximum...more

The DOL Has Made This New Mental Health Parity Requirement a Top Enforcement Priority

Embedded in the Consolidated Appropriations Act, 2021 (the “CAA”) is a new obligation for group health plan sponsors and insurers that provide health insurance to document that their group health plan or insurance policy...more

New California Mental Health Law May Affect Health Plan Benefits and Utilization Review

California health insurers and health care service plans that provide hospital, medical, or surgical coverage and that are issued, amended, or renewed on or after January 1, 2021 will be required to cover all medically...more

Interim Final Rule on Defined Contribution Plan Lifetime Income Disclosures

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

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