News & Analysis as of

Consolidated Appropriations Act (CAA) Employee Benefits Employer Group Health Plans

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

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

Ballard Spahr LLP

Mental Health Brake: 2024 MHPAEA Regulations Put on Hold

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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

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

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

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

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

Epstein Becker & Green

Three Things That Employer Health Plan Sponsors Should Do When the New MHPAEA Rules Are Published

Epstein Becker & Green on

The U.S. Departments of Labor (DOL), Health and Human Services, and the Treasury (collectively, the “Tri-Departments”) published a Notice of Proposed Rulemaking (NPRM) on August 3, 2023, to propose new regulations for the...more

Jackson Lewis P.C.

Health Plan Hygiene Part 1: A Spoonful of Sugar Helps the Medicine Go Down

Jackson Lewis P.C. on

During the next several weeks, we will publish a series of articles that dive deeply into “health plan hygiene” relating to health and welfare benefit plan fiduciary issues and how employers can protect themselves in this...more

Verrill

RxDC Reporting in Light of June 1, 2024 Deadline and Recent PBM Litigation

Verrill on

Under the Consolidated Appropriations Act of 2021 (“CAA”), employer-sponsored group health plans, including medical-only plans, must submit information about their prescription drugs and health care spending. This submission...more

Woodruff Sawyer

Compliance Alert: Reminder: RxDC Reporting Due June 1st

Woodruff Sawyer on

As a reminder, the Consolidated Appropriations Act, 2021 includes a provision that requires group health plans and health insurance issuers (collectively “plans and issuers”) to report certain specified data related to...more

McGuireWoods LLP

A New Frontier for ERISA Fee Suits: Group Health Plans

McGuireWoods LLP on

Best practices in the area of ERISA health and welfare plan governance are evolving. Concerned group health plan fiduciaries have been evaluating compliance processes while facing a set of rigorous fiduciary duties imposed by...more

Littler

Sponsoring a Group Health Plan for Employees? What Employers Need to Know About the Consolidated Appropriations Act

Littler on

Many employers offer health insurance as a way to recruit and retain talent. Sponsoring a group health plan, however, can subject the employer plan sponsor to significant legal and regulatory burdens deriving from laws such...more

Baker Donelson

Surprise! Gag Clause Attestation Due by 12/31/2023

Baker Donelson on

As part of the No Surprises progeny of legislation seeking transparency in health care, the Consolidated Appropriations Act of 2021 prohibits the use of "gag clauses" in group health plan agreements. All group health plans...more

Alston & Bird

Year-End Health Benefits Roundup 2023

Alston & Bird on

It was a lively year for health benefits. Our Employee Benefits & Executive Compensation Group unpacks 2023, from the end of the COVID-19 emergencies to the much-anticipated Mental Health Parity and Addiction Equity Act...more

Jenner & Block

Client Alert: Group Health Plan “Gag Clause” Compliance Attestation Due by the End of 2023

Jenner & Block on

This is a reminder that a new compliance deadline is on the horizon for group health plans. The Consolidated Appropriations Act (CAA) of 2021 generally prohibits group health plans and health insurance issuers from entering...more

Bass, Berry & Sims PLC

Let the Plan Speak: First Gag Clause Attestation Due December 31, 2023

Bass, Berry & Sims PLC on

By December 31, 2023, group health plans and health insurance issuers must submit an attestation to certify compliance with the “gag clause prohibition” under the Consolidated Appropriations Act of 2021 (CAA)....more

Faegre Drinker Biddle & Reath LLP

Reminder: Gag Clause Attestations Due by Year-End

The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...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

Ballard Spahr LLP

Attestation to Consolidated Appropriations Act’s “Anti-Gag Rules” Due by Year’s End

Ballard Spahr LLP on

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

Bradley Arant Boult Cummings LLP

Making the First “Gag Clause” Attestations: A Quick Reference Guide

Under the Consolidated Appropriation Act of 2021 (CAA), group health plans and health insurance issuers are prohibited from entering into agreements with service providers restricting certain information that the plan may...more

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

Ballard Spahr LLP on

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

Seyfarth Shaw LLP

Who Do I Need to Sue to Get a Decent Cup of Coffee? Jittery Fiduciaries Consider Options as Health Plan Litigation Froths Up

Seyfarth Shaw LLP on

Seyfarth Synopsis: In light of a recent focus on price transparency, claims data, and hidden fees in the health plan world, employer-sponsored health plans have been bringing their fight to the courtroom in an effort to lower...more

Dickinson Wright

Avoiding the Storm of Excessive Fee Litigation: How Fiduciaries of ERISA Health Plans Can Get Ahead of the Weather

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For some group health plan fiduciaries, there could be a storm brewing. Changes to the Employee Retirement Income Security Act of 1974 (“ERISA”), buried within the 5,593 pages of the Consolidated Appropriations Act, 2021...more

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