News & Analysis as of

Benefit Plan Sponsors Disclosure Requirements Employer Group Health Plans

Lathrop GPM

Call for Additional Regulations for Health Plan Compensation Disclosures

Lathrop GPM on

In an April 15 Executive Order, entitled “Lowering Drug Prices by Once Again Putting Americans First,” the Trump Administration has called attention to an ERISA disclosure required by the Consolidated Appropriations Act of...more

Polsinelli

Complying with the ACA Disclosure Requirements Just Got a Whole Lot Easier!

Polsinelli on

New legislation liberalizing certain disclosure requirements under the Affordable Care Act (“ACA”) was passed at the end of 2024.  Effective for 2024 reporting, mailing a paper copy of Forms 1095-C/1095-B is no longer...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

2025 ACA Compliance Updates: Essential Insights for Employers

As we turn the page to 2025, employers and HR professionals are turning their attention to ensuring compliance with the reporting and disclosure requirements of the Affordable Care Act (ACA). ...more

Wiley Rein LLP

PBM Contracting and Administration: What Are the Rules of the Road for Self-Insured Employees?

Wiley Rein LLP on

In February 2024, a group representing (among others) the Johnson & Johnson Group Health Plan and its component plans (Plaintiffs) sued Johnson & Johnson and The Pension & Benefits Committee of Johnson and Johnson (J&J) over...more

Williams Mullen

Annual Employee Benefits Compliance Checklists: Plan Administrators of Governmental and Church Plans

Williams Mullen on

Administrators of governmental plans and church plans that are not subject to the Employee Retirement Income Security Act of 1974 (ERISA) should review the following actions to be taken before the end of 2024 and address what...more

Williams Mullen

Annual Employee Benefits Compliance Checklists - Plan Administrators

Williams Mullen on

Plan administrators should review the following actions to be taken before the end of 2024 and focus on what to expect for 2025. The following checklist addresses plan amendments, notices, and other considerations for...more

Schwabe, Williamson & Wyatt PC

Year-End Compliance Considerations for Employee Benefit Plans

Open enrollment is right around the corner (at least for employers that run calendar-year health benefit plans), so many employers will be updating their benefit communication plans. Though not comprehensive, the following is...more

Laner Muchin, Ltd.

Employers Face Another Annual Disclosure for their Group Health Plan Related to the No Surprises Act: “Gag Clauses”

Laner Muchin, Ltd. on

The No Surprises Act (the NSA) bans “gag clauses” that prevent disclosure of price or quality information in agreements between health plans and certain service providers. In addition, the NSA requires plan sponsors to attest...more

Bass, Berry & Sims PLC

Enforcement of the Transparency in Coverage Public Disclosure Requirement Rapidly Approaching

Bass, Berry & Sims PLC on

Starting July 1, 2022, employers that maintain group health plans (plans) and health insurance issuers (issuers) will be required to disclose pricing information on a public website in the form of three machine-readable files...more

Faegre Drinker Biddle & Reath LLP

Deadline Approaches for Employers to Post Machine-Readable Files on a Public Website

The July 1st deadline is quickly approaching for non-grandfathered group health plans and issuers to publicly disclose, in accordance with the Transparency in Coverage Final Rules, price information in machine-readable files...more

Baker Donelson

Transparency in Coverage Rules

Baker Donelson on

Seeking to improve transparency in the cost of health services, federal actions in the past few years have led to new federal rules and regulations for health systems, benefit administrators, and health plan sponsors. The...more

Williams Mullen

Health Plan Transparency Requirements are Effective Now

Williams Mullen on

The Consolidated Appropriations Act, 2021 (“CAA” or the “Act”) includes several transparency requirements for health plans. Some of these requirements are already in effect for plan years beginning on or after January 1,...more

Snell & Wilmer

An Interesting Intersection: No Surprises Act Claims and the New Fee Disclosure Requirements for Group Health Plans

Snell & Wilmer on

As reported in our January 7, 2022 SW Benefits Blog “The DOL Asks and Answers Questions About the New Welfare Plan Fee Disclosure Rules,” group health plans must now comply with the ERISA Section 408(b)(2) disclosure...more

McAfee & Taft

New health plan disclosure requirements should bring more transparency

McAfee & Taft on

Ten years ago, the U.S. Department of Labor (DOL) published a final regulation under the Employee Retirement Income Security Act of 1974 (ERISA) that required retirement plan service providers to disclose information about...more

Verrill

You Are Here: A Mall Directory for Healthcare Transparency Requirements

Verrill on

The old adage “you can’t get where you’re going unless you know where you are” has never seemed more true than when applied to the current mélange of healthcare transparency guidance. Fortunately, a fading relic from...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Dickinson Wright

Group Health Plan Transparency Disclosure Rules Finalized: What Plan Sponsors Should Know

Dickinson Wright on

The Department of Labor (DOL), the Internal Revenue Service (IRS) and the Department of Health and Human Services (HHS) (collectively, Agencies) issued final regulations in November 2020 requiring non-grandfathered group...more

Fisher Phillips

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

Fisher Phillips on

The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

Williams Mullen

Department of Labor Issues Guidance on Continued COVID-19 Timeframe Relief

Williams Mullen on

Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) jointly offered extensions and other relief to employee benefit plan administrators who might be struggling to meet various filing, notice,...more

Proskauer - Employee Benefits & Executive...

ERISA Disclosure Requirements for Service Providers Extended to Group Health Plans

The recently enacted Consolidated Appropriations Act of 2021 (“CAA”) requires new disclosures for brokers and other consultants providing services to certain group health plans. Under the CAA, “covered service providers”...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Consolidated Appropriations Act Requirements to Increase Health Plan Transparency

The Consolidated Appropriations Act (CAA), 2021, which was signed into law December 27, 2020, includes provisions designed to increase transparency in employee health benefit plans in four key areas. Removal of Gag Clauses...more

Proskauer - Employee Benefits & Executive...

Digging into the New HRA Regulations, Part 2 – ERISA Implications

New regulations issued by the Departments of Labor, Treasury, and Health and Human Services have expanded the use of health reimbursement accounts (“HRAs”) by allowing reimbursements for individual market insurance premiums....more

Foley & Lardner LLP

Final Disability Claims and Appeals Regulations – Be Prepared to Comply

Foley & Lardner LLP on

In December 2016, the Department of Labor issued final regulations under ERISA governing claims procedures for group disability plans, which will become effective January 1, 2018. Generally, these regulations were drafted to...more

King & Spalding

November and December 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

King & Spalding on

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more

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