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One Big Beautiful Bill: Impact on Welfare Benefits

President Donald Trump signed the One Big Beautiful Bill (OBBB) into law on July 4, 2025. The OBBB is a wide-ranging piece of legislation that introduces significant reforms across multiple areas of federal policy, including...more

Mental Health Parity Non-Enforcement Statement Released

The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) announced their non-enforcement policy on May 15, 2025, indicating they will not enforce any new requirements imposed by the...more

HHS Issues Final Regulations on Section 1557: Implications for Health Plans

The US Department of Health and Human Services (HHS) recently issued final regulations implementing Section 1557 of the Patient Protection and Affordable Care Act, which will restore and expand the scope of civil rights...more

Managing Welfare Plan Risk: The Fiduciary Committee

Fiduciary committees have long been established in connection with retirement plans to manage the investment, legal compliance, and operational risks that can arise under the Employee Retirement Income Security Act of 1974,...more

First Gag Clause Attestations Due From Group Health Plans by December 31

The Consolidated Appropriations Act, 2021 (CAA), requires group health plans and insurers to annually attest that they are in compliance with the gag clause prohibition under the CAA. The first attestation is due no later...more

Plan Sponsors and Fiduciaries: Some Clarity on Mental Health Parity Compliance

A recently issued White House Fact Sheet, along with a regulatory package from the US Departments of the Treasury, Labor, and Health and Human Services (the Departments), provides some welcome clarity for plan sponsors and...more

Surprise! Texas District Court Strikes Down Portions of No Surprises Act

In the case of Texas Medical Ass'n, et al. v. US Department of Health and Human Services, et al., the US District Court for the Eastern District of Texas on February 23 invalidated portions of the second interim final rule...more

IRS Issues Guidance Regarding American Rescue Plan Act COBRA Subsidy

The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more

DOL Issues ARPA COBRA Subsidy Model Notices and FAQs

As we described in our March 15, 2021 LawFlash, the American Rescue Plan Act of 2021 (ARPA) includes a 100% COBRA premium subsidy for any employee or dependent who is a COBRA qualified beneficiary ...more

American Rescue Plan’s Health and Welfare Benefit Provisions: COBRA and DCFSA Action Items

The American Rescue Plan Act of 2021 includes a COBRA premium subsidy and increases the dependent care flexible spending account (DCFSA) limits. While the availability of the COBRA premium subsidy is a requirement, the...more

Mental Health Parity Transparence: Consolidated Appropriations Act, 2021

As we addressed in our recent LawFlash covering the Consolidated Appropriations Act, 2021 (Act), the Act includes several requirements to enhance group health plan transparency. One provision we wanted to further highlight...more

Consolidated Appropriations Act, 2021: Health and Welfare Provisions

The Consolidated Appropriations Act, 2021 (Act) that was signed into law on December 27, 2020 contains provisions impacting employer sponsored group health plans, including protecting group health plan participants from...more

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