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Stuck in the Middle: Self-Funded Health Plans and Recent Challenges to State PBM Laws

In recent years, prescription drug prices have been top-of-mind for state legislators, who have responded by passing laws that seek to control that pricing in a variety of ways, including by regulating pharmacy benefit...more

Updated Voluntary Fiduciary Correction Program for ERISA Plans Includes Self-Correction Features

As announced in our previous HR Law Talk blog post, on January 15, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published a much anticipated amended and restated version of the...more

BREAKING: DOL Expands the Voluntary Fiduciary Correction Program

Yesterday, the U.S. Department of Labor (DOL) published in the Federal Register an updated version of the Voluntary Fiduciary Correction Program (VFCP) under Title I of ERISA. Per the DOL, VFCP “is designed to encourage...more

Let the Plan Speak: First Gag Clause Attestation Due December 31, 2023

By December 31, 2023, group health plans and health insurance issuers must submit an attestation to certify compliance with the “gag clause prohibition” under the Consolidated Appropriations Act of 2021 (CAA)....more

New Proposed Mental Health Parity Rules Amid Report of Widespread Failure

On July 25, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the Departments) released new Proposed Rules (Proposed Rules) that clarify certain requirements imposed by the...more

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