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

Warner Norcross + Judd

Delayed Enforcement of Mental Health Parity NQTL Comparative Analysis Final Regulations

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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

Jackson Lewis P.C.

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

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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

Alston & Bird

Final Mental Health Parity Rules: A Plan Sponsor’s Implementation Guide

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Our Employee Benefits & Executive Compensation Group discusses what health plan sponsors need to know about the final rule on nonquantitative treatment limitations (NQTLs) and NQTL comparative analysis under the Mental Health...more

Snell & Wilmer

2024 End-of-Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...more

Verrill

Final Mental Health Parity Rule Spells Compliance Changes

Verrill on

The long-anticipated final rule under the Mental Health Parity and Addiction Equity Act (MHPAEA) was published on September 9, 2024. The MHPAEA prohibits group health plans that provide mental health and substance use...more

Foley & Lardner LLP

Final Mental Health Parity Rules – Top Five Changes to the Status Quo

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The Mental Health Parity and Addiction Equity Act and its implementing regulations and guidance (MHPAEA) prohibit health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD)...more

Hall Benefits Law

DOL, HHS, and Treasury Release FAQs about No Surprises Act after TMA III

Hall Benefits Law on

The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and Treasury, along with the Office of Personnel Management (OPM), released FAQs about the implementation of Title I of Division BB of the Consolidated...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Bond Schoeneck & King PLLC

Don’t Choke on the Gag Clause Prohibition Compliance Attestation Requirement of the CAA

On or before Dec. 31, 2023, certain group health plans and health insurance issuers must submit an attestation to the U.S. Department of Health and Human Services (HHS) certifying their compliance with the “gag clause...more

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

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Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more

Snell & Wilmer

2022 End of Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Mintz - Employment Viewpoints

Health Plan Transparency and the Case for Welfare Plan Fiduciary Committees

The Consolidated Appropriations Act, 2021 (the “Act”) adopted a series of transparency requirements that apply to employer-sponsored group health plans. These transparency rules impose a series of new and complex obligations...more

Holland & Hart - The Benefits Dial

What Happens in a Small Town Stays in a Small Town … Until the DOL Doubles Down on Mental Health Parity Compliance

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued their joint report to Congress regarding their Mental Health...more

Ballard Spahr LLP

The CAA Prescription Drug Benefit Reporting Requirement

Ballard Spahr LLP on

Summary - The Consolidated Appropriations Act, 2021 (CAA) requires group health plans and health insurers to submit information regarding the costs of prescription drug costs and other health care services each year to the...more

Ballard Spahr LLP

The CAA's New Rules for Health Care Provider Directories

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Summary - The Consolidated Appropriations Act (CAA) requires each group health plan and health insurer with a network of providers to maintain a database on a public website that lists the name, address, specialty,...more

Epstein Becker & Green

2022 Mental Health Parity Report to Congress Highlights Increased Enforcement Efforts

On January 25, 2022, the U.S. Department of Labor (“DOL”), Department of Health and Human Services, and Department of the Treasury (collectively, “Departments” or “Regulators”) released their 2022 Annual Report to Congress on...more

Ballard Spahr LLP

The CAA's New Identification Card Requirements

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Summary - To help individuals better understand the costs they will bear for medical care, the Consolidated Appropriations Act (CAA) requires health plan ID cards to include clear information about deductibles and...more

Sheppard Mullin Richter & Hampton LLP

Tri-Agencies Report MHPAEA Compliance Lacking, But Don’t Name and Shame Plans and Issuers . . . Yet

On January 25, the U.S. Department of Labor (DOL), Department of Health and Human Services (HHS), and the Treasury (collectively the Tri-Agencies) published the first annual report on group health plans’ and health insurance...more

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

Making a List, Checking It Twice: Year-End Guidance on Drug Cost Reporting

Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data - but no more time to comply with - daunting prescription drug cost reporting requirements in the...more

Mintz - Employment Viewpoints

Broker and Consultant Disclosures to Group Health Plans under Division BB of the Consolidated Appropriations Act, 2021

Division BB of the Consolidated Appropriations Act, 2021 (“Act”) broadly addresses surprise medical billing and health plan transparency. This post focuses on Section 202 of Division BB (the “Provision”), which establishes...more

Foley & Lardner LLP

The Consolidated Appropriations Act’s Compensation Disclosure Provisions from a Carrier and Plan Service Provider Perspective

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...The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) sets forth new compensation disclosure requirements that apply to brokers and consultants with respect to both fully-insured and self-insured group health...more

Groom Law Group, Chartered

HHS Issues Proposed Rules Implementing the Individual Health Insurance Agent & Broker Fee Disclosure Requirements

As we discussed in our earlier summary, the Consolidated Appropriations Act, 2021, Public Law 116-260 (“CAA”), signed into law by the President on December 27, 2020, imposed new compensation disclosure requirements upon...more

Verrill

Employee Benefits & Executive Compensation 2021 Summer Client Advisory

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This Client Advisory summarizes developments in the law governing employee benefit plans prompted by the COVID-19 pandemic. We explain what these developments mean for plan sponsors and highlight the need to adopt plan...more

Holland & Knight LLP

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

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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

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