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Final Rules Related to the Mental Health Parity and Addiction Equity Act May Drive You Wild

Seyfarth Synopsis: On September 9, 2024, the Departments of the Treasury, Labor, and Health and Human Services (the “Departments”) released highly anticipated Final Rules under the Mental Health Parity and Addiction Equity...more

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Mental Health Parody: In A Cruel Prank, Agencies Respond to Employer Pleas for Guidance with More Stringent Regulations

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

New Guidance on Gag Clause Attestation

Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may...more

We Have No Idea When The Outbreak Period Will End, But We Have a Better Idea When COBRA Payments are Due

Seyfarth Synopsis: The IRS has attempted to provide clarity (following the DOL’s earlier attempt) on how the coronavirus Outbreak Period will work and how it applies  to COBRA election and premium payment deadlines, in Notice...more

IRS Releases Extensive Guidance on ARPA COBRA Subsidy

Seyfarth Synopsis: On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”), which requires plan sponsors to provide free COBRA coverage from April 1, 2021 through September 30, 2021, to...more

DOL Issues Clarification of Outbreak Period - Sort of

At the 11th hour, on February 26, 2021, the Department of Labor (DOL) issued EBSA Disaster Relief Notice 2021-01 (the “Notice”) to provide guidance on the duration of the COVID-related relief previously provided by the DOL in...more

The Biden Administration Removes Limits on Agency “Guidance” – And Creates A New Agenda Enforcement Tool

Synopsis: On January 20, 2021, the Biden Administration revoked the Trump Administration Executive Order (EO) which had restricted agency Guidance. On January 27, 2021, the Department of Labor (DOL) rescinded the “PRO Good...more

Final Rule regarding Transparency in Coverage for Health Care Services

Seyfarth Comments: The final Transparency in Coverage Rule was published jointly by the Departments of Health and Human Services, Treasury, and Labor on November 12, 2020. The Rule aims to increase transparency in...more

The Department of Labor Puts Limits on “Guidance” — And Employers and Fiduciaries May Get More Interpretative Flexibility

Synopsis:  On August 28, 2020, the federal Department of Labor (DOL) issued a final rule entitled “Promoting Regulatory Openness Through Good Guidance” (the “PRO Rule”) that establishes a data base with far fewer “Guidance”...more

Oh What a Relief It Is - For Health Plan Participants

Seyfarth Synopsis: On Tuesday, shortly after the IRS extended deadline relief to employee benefit plans, the U.S. Department of Labor granted its own relief for a number of deadlines related to the administration of employee...more

Issue 117: DOL Issues Proposed Rules On Association Health Plans

This is the one hundred and seventeenth issue in our series of alerts for employers on selected topics on health care reform. This series of Health Care Reform Management Alerts is designed to provide an in-depth analysis...more

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