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Centers for Medicare & Medicaid Services (CMS) Employer Group Health Plans Health Insurance

Lathrop GPM

Administration Issues Cross-Agency Guidance Targeting Health Care Pricing and Focusing on Hospitals and Health Plans

Lathrop GPM on

On May 22, 2025, the U.S. Department of Health and Human Services, Department of Treasury and Department of Labor (the “Agencies”) announced new steps intended to “strengthen healthcare price transparency.” ...more

Venable LLP

June 1, 2025 Prescription Drug Reporting Deadline for Group Health Plans

Venable LLP on

Employer group health plans must make an annual disclosure of the plan's prescription drug and healthcare spending to the Centers for Medicare & Medicaid Services (CMS). The disclosure, called the Prescription Drug Data...more

Groom Law Group, Chartered

CMS Finalizes Updates to the Prescription Creditable Coverage Methodology Determination

In April 2025, the Centers for Medicare and Medicaid Services (“CMS”) issued multiple pieces of guidance related to Medicare Part D prescription drug coverage, including the Final CY 2026 Part D Redesign Program Instructions....more

McDermott Will & Schulte

Food as Medicine: A Deep Dive Into Reimbursement

The topic of “food as medicine” has gained increased attention recently, driven by a growing recognition of the role nutrition plays in preventing and managing chronic diseases. This article provides a high-level overview of...more

Fenwick & West LLP

California’s SB 1120 Regulates AI in Health Plan Utilization Review and Management Activities Starting in January

Fenwick & West LLP on

On September 28, California Gov. Gavin Newsom signed Senate Bill 1120 Health Care Coverage: Utilization Review into law, amending § 1367.01 of the Health and Safety Code and § 10123.135 of the state’s Insurance Code....more

Bass, Berry & Sims PLC

More Losses than Gains? OIG Declines to Approve Certain Medicare Advantage Gainsharing Arrangements in Advisory Opinion 24-08

Bass, Berry & Sims PLC on

On September 13, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 24-08, in which it declined to approve a proposal by a Medicare Advantage organization (MAO)...more

Bricker Graydon LLP

Summer's Hot Debate: Does a Self-Funded Group Health Plan Cover Gender-Affirming Care?

Bricker Graydon LLP on

As the temperatures continue to rise, regulations and litigation related to employer-sponsored group health plans have followed suit. As these new rules continue to evolve, we are often asked whether a self-insured group...more

Akerman LLP - HR Defense

On the Basis of Sex… Discrimination in Group Health Plans and What Employers Should Know

In just a few days’ time, recently promulgated federal final rules addressing sex-based nondiscrimination in the administration of health care benefits have created a flurry of healthcare industry activity. The angst arises...more

Genova Burns LLC

Heads Up To Group Health Plans: December 31 Gag Clause Attestation Deadline Approaches

Genova Burns LLC on

The Consolidated Appropriations Act of 2021 prohibits group health plans from agreeing to avoid making certain disclosures of provider-specific cost or quality-of-care information. This is referred to as the gag clause...more

Stevens & Lee

Gag Clause Prohibitions in ERISA, the Internal Revenue Code and the Public Health Service Act

Stevens & Lee on

If you work for or represent group health plans or issuers of group health plans, it is important that you take a look at the contracts they have with health care providers before the end of 2023. The Internal Revenue Code...more

Pullman & Comley - Labor, Employment and...

Group Health Plans and Medicare Secondary Payer Rules: Do the Mandatory Reporting Obligations Apply to You?

The Medicare Secondary Payer provisions (MSP) apply to group health plans sponsored by employers with 20 or more employees, in both the private and public sectors. MSP’s mandatory reporting requirements are designed to...more

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

Morgan Lewis - ML Benefits

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

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

Proposed Rules Push Mental Health Parity Up Benefit Priority List

Now you know. It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more

Faegre Drinker Biddle & Reath LLP

DOL Issues Long Awaited Mental Health Parity Guidance

Plan sponsors, insurers, and third-party administrators should pay close attention to the new guidance to facilitate health plan compliance with complex nonquantitative treatment limitation comparative analyses requirements....more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Verrill on

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Husch Blackwell LLP

New Federal Guidance on Employer-Sponsored Group Health Plans and Required Action Steps for 2023

Husch Blackwell LLP on

The Consolidated Appropriations Act, 2021 (CAA) prohibits employer-sponsored group health plans from entering into agreements that contain so-called “gag clauses.” This prohibition generally restricts group health plans from...more

Venable LLP

REMINDER: October 15 Is the Deadline for Prescription Drug Notices and the Extended Deadline for Form 5500s

Venable LLP on

Does your company's health plan provide prescription drug coverage? If so, you have until October 15, 2022 to send a notice to individuals who are enrolled in Medicare Part A or Part B and are eligible for the company's...more

Jackson Lewis P.C.

4th Quarter 2022 Quick Hits for Plan Sponsors and Administrators

Jackson Lewis P.C. on

As we enter the fourth quarter of 2022, sponsors and administrators of employee benefit plans have a lot to juggle. From open enrollment and required notices to plan document deadlines, it is a busy time of year. Yet, there...more

Nelson Mullins Riley & Scarborough LLP

Reminder – Medicare Part D Notices due October 15, 2021

Group health plan sponsors must provide annual Medicare Part D Notices (the “Notice” or the “Notices”) by October 15, 2021. It’s your last chance to make sure your Notices will be timely delivered and comply with the legal...more

Holland & Knight LLP

HHS Issues Interim Final Rule Implementing Certain Provisions of the No Surprises Act

Holland & Knight LLP on

The U.S. Departments of Health and Human Services (HHS), Labor and Treasury, along with the Office of Personnel Management, on July 1, 2021, issued a much-anticipated Interim Final Rule with Comment Period (IFC) –...more

Nelson Mullins Riley & Scarborough LLP

Reminder – Medicare Part D Notices due October 15, 2020

Group health plan sponsors must provide annual Medicare Part D Notices by October 15, 2020. Now is a good time for you to check to make sure your Notices will be timely delivered and comply with the legal requirements. Read...more

Brownstein Hyatt Farber Schreck

Health Plan Coverage of Coronavirus Testing and Treatment

With the news about the spread of the 2019 novel coronavirus (“COVID-19”) in the U.S. and the world rapidly evolving, group health plan sponsors need to address how the plan will provide virus-related benefits. ...more

Foley & Lardner LLP

Massachusetts Governor Proposes Facility Fee Ban

Foley & Lardner LLP on

Massachusetts Governor Charlie Baker has restarted the discussion on health care cost containment in the Commonwealth with a proposed bill that contains a raft of initiatives. This is the first in a series of blog posts to...more

Mintz - Employment Viewpoints

Association Health Plan Perspectives (Part 2): The Look-Through Rule and the Limits of State Regulatory Power

In a summary of the recently issued Association Health Plan (AHP) final regulations, the U.S. Department of Labor (DOL) rightly observed that AHPs are a species of multi-employer welfare arrangements, or MEWAs, that are...more

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