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Considerations for Group Health Plans as COVID-19 Emergency Declarations End

Part I: COVID-19 Diagnostic Testing Coverage - On January 30, 2023, the Biden Administration announced that it intends for the National Emergency (NE) relating to the COVID-19 pandemic to end on May 11, 2023....more

Preparing for the End of the COVID-19 Emergency Declarations: Part I. Considerations for COVID-19 Diagnostic Testing Coverage

On January 30, 2023, the Biden Administration announced that it intends for the National Emergency (“NE”) relating to the COVID-19 pandemic to end on May 11, 2023. Shortly after, the Secretary of the Department of Health and...more

Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting

On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are...more

Just in the Nick of Time – Congress Grants Second Extension of CARES Act Telehealth/HSA Relief

Recently Congress passed the Consolidated Appropriations Act of 2023 (“2023 CAA”). Among other things, the 2023 CAA extends, for a second time, the telehealth relief provided under the CARES Act. The CARES Act permitted high...more

Agencies Issue Guidance Requiring Coverage for Over-the-Counter COVID-19 Tests

Beginning January 15, 2022, and through the duration of the public health emergency, insurers and group health plans must cover at-home COVID-19 diagnostic tests available over-the-counter (OTC) without imposing cost-sharing,...more

Agencies Issue COVID-19 Vaccine Incentive Guidance

On October 4, 2021, the U.S. Department of Health and Human Services, U.S. Department of Labor and U.S. Department of the Treasury jointly issued FAQs relating to COVID-19 vaccine incentives and surcharges. Under the...more

COBRA Premium Assistance Expiration Notice Deadline Approaching

The COBRA premium assistance period, as part of the American Rescue Plan Act, will expire on September 30, 2021. Plans are required to send notices to assistance eligible individuals (AEIs) to inform them about the subsidy's...more

IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA

On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the...more

American Rescue Plan Act Contains Many Employee Benefits Related Provisions

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the “ARPA”) into law.  Many of the provisions in this sweeping legislation bring changes to the employee benefits world of which employers should...more

IRS Guidance on CAA Coronavirus Relief for FSAs, DCAPs and Cafeteria Plans

On February 18, 2021, the IRS issued Notice 2021-15, clarifying temporary special rules for cafeteria plans, health flexible spending accounts (FSAs) and dependent care assistance programs (DCAPs) that were included in the...more

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