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The HDHP Telehealth Safe Harbor Returns – For Good This Time

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

Action Steps Health Plans Should Take Now In Response To New DOL Guidance on Mental Health Parity

The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...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

Upcoming Deadline Under The No Surprises Act – Air Ambulance Reporting By Group Health Plans and Insurance Issuers

Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...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

Group Health Plans Subject to New Prescription Drug and Health Care Spending Reporting Requirements

Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...more

Employer Checklist for New Health Plan Price Transparency Rules and CAA

The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...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

Can You Add Your Parents to Your Health Plan? California Considers It

12% of parents in the United States with children under age 18 are also caring for another adult. The number of caregivers who provide unpaid care for a family member over the age of 50 has increased in the past five years,...more

IRS Provides New Flexiblity for Cafeteria Plan Elections

The IRS issued two notices on May 12, 2020, Notice 2020-29 and Notice 2020-33. These Notices provide a number of options that employers could choose to offer their employees with respect to their 2020 cafeteria plan benefits...more

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