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Supreme Court Decision Leaves ACA Preventive Services Mandate Intact

On the last day before the U.S. Supreme Court’s summer recess, the Court issued a decision that left in place the Affordable Care Act (“ACA”) mandate that requires non-grandfathered group health plans and issuers to cover,...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

Recent Health Plan Litigation Puts Family Building Benefits in Focus

Family building benefits continue to be top of mind as employers and plan sponsors implement new benefit programs to support family building journeys for their employees. At the same time, there have been a few recent...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

For HDHPs, IRS Confirms Pre-Deductible COVID-19 Testing Coverage Will End Next Year

In the most recent sign that special COVID-19 benefit plan rules are drawing to a close, last Friday, the IRS issued Notice 2023-37, which clarifies the scope of COVID-19 testing and treatment that can be provided on a...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

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

After Dobbs v. Jackson Women’s Health Organization: Impact on Employee Benefits

Employers and other group health plan sponsors are left with much to consider following the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, which overruled the Supreme Court’s prior landmark...more

Post-Dobbs: FAQs for Employers and Other Benefit Plan Sponsors

Can group health plans continue to provide coverage for abortion-related expenses? In short, yes. Dobbs does not prohibit group health plans from covering abortion-related expenses. Instead, Dobbs eliminates federal...more

There’s More! Tri-Agencies Provide Clarifying Guidance on Group Health Plan Coverage of Over-the-Counter At-Home COVID-19 Tests

A few short weeks ago we told you in a blog post that, with only four days’ notice, the Departments of Labor, Treasury, and HHS (the Departments) required that, starting January 15, 2022, group health plans cover FDA-approved...more

You Can Go Home Again: Tri-Agencies Release New Group Health Plan Coverage Requirements for Over-the-Counter At-Home COVID-19...

Looking forward to the weekend? Many employers and plan administrators may also have been . . . up until yesterday, when the government issued new requirements that take effect on Saturday. ...more

Guide to New IRS Guidance on COBRA Premium Subsidy

On May 18, 2021, the IRS released Notice 2021-31, which provides implementation guidance on the COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARP). As discussed in our prior blog posts, ARP...more

DOL Releases COBRA Premium Subsidy Model Notices – With a Few Surprises

Immediate Action Required - As discussed in our prior posts, the American Rescue Plan Act of 2021 (“ARP”) requires that plan administrators distribute new COBRA notices advising individuals of their possible rights to a...more

ARPA COBRA Subsidy – Special Second Election Period (Two Bites at the Apple and Some Additional Food for Thought)

The American Rescue Plan Act of 2021 (“ARPA”) provides a 100% COBRA premium subsidy for “assistance eligible individuals” for periods of coverage occurring between April 1, 2021 and September 30, 2021. An “assistance...more

SECURE Act: Two Key Changes for Defined Benefit Plans

As part of our ongoing series on the SECURE Act, this post discusses two key changes affecting defined benefit plans: (1) the ability to start in-service distributions at age 59½ (reduced from 62), and (2) new tools for...more

ERISA Newsletter - Third Quarter 2019

In this edition of our Newsletter, we take a look at a pair of cases that, while unrelated, together remind us of the importance of having clear plan rules in place that reflect the plan sponsor’s intention. The first article...more

District Court Denies Motion to Dismiss Mental Health Parity Act Putative Class Action

In the latest volley between participants and group health plans over mental health services coverage, a federal district court in California denied United Healthcare’s motion to dismiss a putative class action challenging...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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