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District Court Vacates HIPAA Reproductive Health Care Rule

Last month, a federal district court in Texas vacated portions of the HIPAA final rule that added heightened protections for reproductive health care information (the “Final Rule”). Purl, et al. v. U.S. Department of Health...more

Departments Press Pause on Final Mental Health Parity Regulations

Yesterday, the Departments of Labor, Treasury, and Health and Human Services announced a non-enforcement policy with respect to final regulations issued under the Mental Health Parity and Addiction Equity Act of 2008...more

How Expanded Birth Control Coverage May Affect Employers

The U.S. Departments of Labor, Treasury, and Health and Human Services proposed regulations last month that would expand group health plans' required coverage of preventive services and contraceptives. Originally published...more

Deadlines Approaching for New ACA Section 1557 Nondiscrimination Requirements: Action Items for Covered Group Health Plans

Earlier this year, the Department of Health and Human Services (“HHS”) released a final rule under Section 1557 of the Affordable Care Act (“ACA”), which prohibits discrimination in health programs and activities. The 2024...more

Agencies Update Guidance on Group Health Plan Contraceptive Coverage Requirements

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently issued guidance for group health plans outlining a “therapeutic equivalence” medical management technique for required preventive...more

Preventive Care in a Post-Braidwood World: Agencies Release Guidance on Preventive Services Coverage Requirements

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently released guidance for group health plans on required preventive services coverage. The guidance was issued in response to a...more

Update: Big Headline, Small Impact: Legislation Ends COVID-19 National Emergency

Important Update: Based on informal comments from the U.S. Department of Labor, it appears that the tolling of benefit plan deadlines will end on July 10, 2023, as described in our earlier blog on this subject,...more

It’s Over: DOL, Treasury, and HHS Confirm End of (Most) COVID-19 Rules for Health Plans

Earlier this week, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) jointly issued guidance confirming that most COVID-19-related benefit coverage mandates, as well as the special tolling...more

Now Live: Tri-Agencies Release Guidance for Group Health Plan “No Gag Clause” Attestations

On February 23, 2023, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued new guidance (in the form of FAQs) implementing the No Surprises Act’s prohibition on “gag clauses” in...more

Digging into the New HRA Regulations Part 4: Excepted Benefit HRAs

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) have expanded the use of health reimbursement arrangements (“HRAs”), including permitting the use of HRAs to...more

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

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