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2022 Mental Health Parity Report to Congress Highlights Increased Enforcement Efforts

On January 25, 2022, the U.S. Department of Labor (“DOL”), Department of Health and Human Services, and Department of the Treasury (collectively, “Departments” or “Regulators”) released their 2022 Annual Report to Congress on...more

The Proposed Expansion of Health Reimbursement Arrangements: Is This a Game Changer for Employers?

On October 22, 2018, in perhaps the most significant guidance resulting from President Trump’s 2017 Executive Order 13813, “Promoting Healthcare Choice and Competition Across the United States” (“2017 Executive Order”), the...more

Association Health Plans: Federal Rule Broadens Opportunities, but Some States Clamp Down

On June 19, 2018, the Trump administration finalized a rule that will enable small businesses and self-employed individuals to band together to offer access to large group health plans, which are typically less expensive (but...more

Association Health Plans: New Proposed Rule to Help Convert Small Businesses and Self-Employed Individuals into a Status Similar...

The Trump Administration has published a proposed rule allowing a significant change to the definition of "employer" under ERISA that would enable small businesses and self-employed individuals to band together to create...more

Assessing President Trump’s “Executive Order Promoting Health Care Choice and Competition”

On October 12, 2017, President Donald Trump signed an executive order (the “Order”) designed to “promote healthcare choice and competition across the United States,” which in effect will allow many Americans to sidestep...more

Nondiscrimination Standards Under ACA Section 1557: Now Is the Time to Act

Health insurers and group health plan sponsors must closely review the final rule titled “Nondiscrimination in Health Programs and Activities” (“Final Rule”) implementing Section 1557 of the Affordable Care Act (“ACA”) that...more

Mental Health Parity Requirements and Medicaid Plans: CMS Seeks Comment on Proposed Rule

On April 10, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published in the Federal Register a proposed rule (“Proposed Rule”) implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction...more

Obama Administration Seeks Comments on Proposed Changes to Summary of Benefits and Coverage Document and Requirements

On December 30, 2014, the Departments of Health and Human Services, Labor, and the Treasury (collectively, “Departments”) issued a proposed rule (“Proposed Rule”) regarding the summary of benefits and coverage (“SBC”) for use...more

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