News & Analysis as of

Consolidated Appropriations Act (CAA)

Ballard Spahr LLP

Courts Split on Enforcement of No Surprises Rules

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The Fifth Circuit and the Federal District Court of Connecticut have issued conflicting decisions on whether service providers may sue to enforce arbitration awards under the No Surprises Rules in the Consolidated...more

Husch Blackwell LLP

MHPAEA July 2025 Update: What Employers and Plans Need to Know about Federal Non-Enforcement

Husch Blackwell LLP on

The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) was enacted to ensure that group health plans and health insurance issuers offering mental health and substance use disorder (MH/SUD) benefits do not impose...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Gag Clause Prohibitions

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses prohibitive gag clauses under the Consolidated Appropriations Act (CAA). While intended to promote transparency, not all gag clauses are...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - May 2025

The May Monthly Minute brings you up-to-date on mental health parity enforcement relief, as well as smoker surcharge and prohibited transaction litigation. Nonenforcement of 2024 Mental Health Parity Regulations - Earlier...more

Littler

The Parity Paradox: MHPAEA Compliance for Employers and Insurers During the 2024 Enforcement Pause

Littler on

The U.S. Departments of Labor, Health and Human Services, and Treasury have announced that they will pause enforcement of the 2024 Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rule (the “2024 Final Rule”) for...more

Warner Norcross + Judd

Delayed Enforcement of Mental Health Parity NQTL Comparative Analysis Final Regulations

Warner Norcross + Judd on

Under the Mental Health Parity and Addiction Equity Act (MHPAEA), as amended by the Consolidated Appropriations Act (CAA), 2021, group health plans and health insurance issuers must conduct comparative analyses to show that...more

Ballard Spahr LLP

Mental Health Brake: 2024 MHPAEA Regulations Put on Hold

Ballard Spahr LLP on

A recent court filing offers a reprieve to health plan sponsors in their efforts to comply with final regulations issued last year under the Mental Health Parity and Addiction Equity Act (MHPAEA)....more

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

Maynard Nexsen

Tri-Agency FAQ Provides Updated Guidance Regarding Compliance with the Gag Clause Prohibition

Maynard Nexsen on

On January 14, 2024, the Departments of Labor, Health and Human Services, and the Office of Personnel Management (the “Departments”) jointly released the FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

Verrill

The Gag Clause Quandary for Self-Insured Group Health Plans—New FAQ Guidance

Verrill on

The Departments of Labor, Health and Human Services, and the Treasury, with the Office of Personnel Management (the “Departments”) jointly released FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

King & Spalding

Congress Considering Bipartisan Legislation to Expand Medicare GME Programs

King & Spalding on

On December 18, 2024, a bipartisan group of four Senators on the Senate Finance Committee released draft legislation that would expand the total number of Medicare Graduate Medical Education (GME) full-time equivalent (FTE)...more

Davis Wright Tremaine LLP

COVID-19 Telehealth Flexibilities Extending and Enduring

In the wake of an end of year filled with intense negotiations and political wrangling, Congress has successfully enacted the American Relief Act, 2025 ("the Budget Bill" or "legislation"), narrowly averting a government...more

King & Spalding

FDA Issues Draft Guidance on Accelerated Approval Focused on How the Agency Will Implement New Authorities

King & Spalding on

On December 5, 2024, the U.S. Food and Drug Administration (FDA or Agency) issued a draft guidance entitled Expedited Program for Serious Conditions—Accelerated Approval of Drugs and Biologics (Draft Accelerated Approval...more

Akin Gump Strauss Hauer & Feld LLP

A New Year, Congress and Trump Administration: 10 Health Issues to Watch in 2025

As the new year begins, change is afoot inside the Beltway as the 119th Congress gets underway and Washington prepares for President Trump’s second administration. While change is bringing uncertainty on some fronts, health...more

Jackson Lewis P.C.

Health and Welfare Plans: Recent Topics in Year-End Compliance

Jackson Lewis P.C. on

As we bid farewell to 2024 and look ahead to the new year, we reflect on the many evolving compliance obligations that health and welfare plan sponsors tackle each year. Although this list is by no means exhaustive, it...more

Holland & Knight LLP

Holland & Knight Health Dose: December 17, 2024

Holland & Knight LLP on

Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector....more

Davis Wright Tremaine LLP

Effective Care: California Left Behind as Other States Expand Hospital at Home Programs

Hospital at Home (“HaH”) programs received renewed interest during the COVID-19 pandemic as a way to relieve hospital capacity issues and allow patients to receive effective care outside of the traditional hospital setting....more

Foley & Lardner LLP

Medicare Telehealth Flexibilities Get a Three-Month Lifeline

Foley & Lardner LLP on

After much uncertainty, Congress has extended many Medicare telehealth flexibilities through March 31, 2025, in its end-of-year appropriations bill. However, several important flexibilities, such as first-dollar coverage of...more

McDermott Will & Emery

Complying With the ‘Relevant Data’ Requirement Under the Final 2024 Mental Health Parity and Addiction Equity Act: A Proposal for...

McDermott Will & Emery on

The Mental Health Parity and Addiction Equity Act (MHPAEA) generally requires group health plans and health insurance issuers to ensure that financial requirements (such as copays and deductibles), quantitative treatment...more

Sheppard Mullin Richter & Hampton LLP

Congress Extends Telehealth Flexibilities for Two More Years

With only two weeks remaining in the year, Congress is considering a government funding deal (the “Further Continuing Appropriations and Disaster Relief Supplemental Appropriations Act, 2025” or the “Bill”) that includes a...more

Snell & Wilmer

Deadline Approaches for Expiring Medicare Telehealth Waivers: What Providers Should Know

Snell & Wilmer on

During the COVID-19 pandemic, both federal and state governments enacted a host of laws and implemented flexibilities to ensure health care providers, hospitals, and health systems could move traditional brick-and-mortar care...more

Dinsmore & Shohl LLP

Is the End Near? Medicare Telehealth Flexibilities Set to Expire at the End of the Year

Dinsmore & Shohl LLP on

The temporary telehealth flexibilities that Medicare patients and providers have become accustomed to since the COVID-19 pandemic are set to expire December 31, 2024. The Consolidated Appropriations Act of 2023 extended many...more

McDermott+

No Surprises Act Implementation Under the Trump Administration

McDermott+ on

The No Surprises Act, a law that ended the practice of “balance billing” by certain out-of-network providers, was enacted as part of the Consolidated Appropriations Act of 2021 on December 27, 2020. While the law passed...more

Akin Gump Strauss Hauer & Feld LLP

FDA Announces Draft Guidance for Industry Regarding Accelerated Approval for Drugs and Biologics

On December 5, 2024, FDA unveiled the draft guidance for industry regarding accelerated approval for drugs and biologics. This guidance provides additional information regarding the development of drugs and biologics to treat...more

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

Don’t Overlook Year-End HDHP Changes to Telehealth Cost-Sharing

Employers providing health plan coverage through a high-deductible health plan (HDHP) may need to amend their HDHP before year-end to remove first-dollar telehealth coverage. Although prior regulatory relief permitted...more

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