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Consolidated Appropriations Act (CAA) Disclosure Requirements Employee Benefits

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

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

Dorsey & Whitney LLP

Courts Address Participant Standing to Challenge Fees and Payments Received by Group Health Plan Service Providers

Dorsey & Whitney LLP on

As we recently suggested, ERISA disputes over the fees and expenses charged to employer or union sponsored group health plans may well become the next wave in ERISA litigation. At minimum, the Consolidated Appropriations Act...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

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Health Plan Transparency Requirements

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt is joined by his colleague, Allison Carlon, who helps us better understand what employers need to know about the Consolidations Appropriations Act...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

Laner Muchin, Ltd.

New Employer Group Health Plan Compliance Obligations for 2022

Laner Muchin, Ltd. on

With each new year, new legal obligations for employers sponsoring group health plans seem to arrive. This article provides a brief overview and reminder of some of the new key requirements for 2022, many of which we have...more

Proskauer - Employee Benefits & Executive...

DOL Announces Temporary Enforcement Policy and Guidance to Address New Compensation Disclosure Requirements for Service Providers...

On December 30, 2021, the U.S. Department of Labor (“DOL”) issued Field Assistance Bulletin No. 2021-03 (“FAB”), announcing its temporary enforcement policy for group health plan service provider disclosures under ERISA...more

Foley & Lardner LLP

CAA Compensation Disclosures: DOL’s New FAB Confirms the Scope is Broad

Foley & Lardner LLP on

The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) set forth new compensation disclosure requirements that apply to service providers who provide “brokerage services” or “consulting” to group health plans...more

Ballard Spahr LLP

Temporary Enforcement Policy Addresses CAA's Health Plan Service Provider Disclosure Requirements

Ballard Spahr LLP on

Summary - The U.S. Department of Labor (DOL) has issued a temporary enforcement policy to address frequently asked questions about the requirement for certain service providers to disclose direct and indirect compensation...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

Husch Blackwell LLP

Federal Government Issues New ERISA Disclosure Requirements: DOL guidance triggers important responsibilities for both service...

Husch Blackwell LLP on

On December 30, 2021, the Department of Labor (DOL) issued a temporary enforcement policy and guidance regarding group health plan service provider disclosures under section 408(b)(2) of the Employee Retirement Income...more

Fisher Phillips

Federal Departments Shed Light on Upcoming Health Plan Disclosure Requirements

Fisher Phillips on

A collection of federal agencies recently released guidance to assist group plan health sponsors navigate upcoming disclosure obligations. On November 17, the Internal Revenue Service, the U.S. Department of Labor, and the...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

Ballard Spahr LLP

Enforcement Delayed Under the New Health Plan Disclosure Requirements

Ballard Spahr LLP on

Summary - Three federal agencies, the Departments of Labor, Health and Human Services, and Treasury, jointly released new FAQs on August 20, 2021, regarding compliance with new health plan disclosure requirements of the...more

Genova Burns LLC

New Disclosure Requirements Service Brokers and Consultants of Group Health Plans

Genova Burns LLC on

Buried in the Consolidated Appropriations Act of 2021 (the “Act”), which is most known for its $2.3 trillion spending bill that combines $900 billion in stimulus relief for the COVID-19 pandemic, are important new rules...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

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

Husch Blackwell LLP

New Fee Disclosures For Health Plan Consultants And Brokers

Husch Blackwell LLP on

The Consolidated Appropriations Act, 2021 expands the service provider compensation disclosure rules to group health plans. Under Section 408(b)(2) of ERISA, any covered service provider that expects to receive at least...more

Roetzel & Andress

Employee Benefits Update: Recent Legislation And Regulations Impose New Obligations On Plan Administrators And Plan Sponsors

Roetzel & Andress on

Congress’s passage of the Consolidated Appropriations Act (“CAA”) imposes a series of new recordkeeping and disclosure obligations on plan sponsors, as well as extending and expanding upon COVID-19 related relief. Less than...more

Nossaman LLP

New Disclosure Requirements for Those that Contract with ERISA Group Health Plans

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Included within the 5539 pages of statutory changes in the Consolidated Appropriations Act, 2021 (the COVID-19 relief bill signed into law at the end of December 2020) are important new “transparency” laws that affect third...more

Ballard Spahr LLP

Stimulus Bill Adds New Disclosure Requirements for Consultants and Brokers to ERISA Health Plans

Ballard Spahr LLP on

The new stimulus bill (the Consolidated Appropriations Act of 2021 or CAA) imposes new disclosure requirements for brokers and consultants providing services to ERISA health plans. The service providers are required to...more

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