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MHPAEA 2024 Final Rule Requires Action by Plan Sponsors

I. Summary of the Final Rule - On September 9, 2024, the Departments of Treasury, Labor and Health and Human Services published the much-anticipated final rule implementing parts of the Mental Health Parity and Addiction...more

Changes to the HIPAA Privacy Rules – A Primer for Self-Insured Group Health Plans

The Office for Civil Rights (“OCR”) of the US Department of Health and Human Services recently released a final rule (“Final Rule”) to update the HIPAA Privacy Rules for reproductive health care information. The Final Rule...more

Regulators Issue Further Guidance on Mandatory Coverage of Over-the-Counter COVID-19 Tests

As we previously discussed, federal regulators released FAQs on January 10, 2022 (“January FAQs”), requiring health plans to cover over-the-counter (OTC) COVID-19 tests for all participants during the pandemic, without...more

Mental Health Parity - New Requirements for Plan Sponsors

On August 12, 2021, the U.S. Department of Labor announced a $15.6 million settlement related to violations of the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). In the news release announcing the...more

COBRA Subsidy - Part II

The American Rescue Plan Act of 2021 (“ARPA”) includes a provision amending the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) to provide COBRA premium assistance to eligible individuals. The ARPA COBRA...more

IRS Extends Transitional Relief for 2020 ACA Reporting

The Internal Revenue Service (IRS) released Notice 2020-76 on October 2, 2020, announcing a delay in the deadline for distribution of Forms 1095-B and Forms 1095-C to participants by employers, health insurers and other...more

Impact of New Department of Labor HRA Regulations on Retiree Only HRAs

On June 13, 2019, the Department of Labor (the “DOL”), along with the Departments of Treasury and Health and Human Services, released final regulations expanding the use of health reimbursement arrangements (HRAs). Since...more

DOL Enforcement Relief Clears Pathway for Association Health Plans

On May 13, 2019, the Department of Labor released additional guidance addressing questions about the enforcement relief announced earlier by the Department pending its appeal of the district court’s ruling that invalidated...more

DOL Appeals Association Health Plan Ruling

On April 26, 2019, the Department of Labor filed a notice of appeal in the case that invalidated key provisions of its Association Health Plan (AHP) regulations. Released last summer, the AHP regulations loosened the...more

Court Ruling Chills Association Health Plans

On March 28, 2019, in State of New York v. United States Department of Labor, a federal district court in the District of Columbia set aside key portions of the Department of Labor’s final rule (the “Final Rule”) which paves...more

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