News & Analysis as of

Consolidated Appropriations Act (CAA) Health Insurance Department of Labor (DOL)

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

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

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

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

McDermott Will & Emery

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

McDermott Will & Emery on

On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...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

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

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

King & Spalding

HHS, the Department of Labor, and the Department of the Treasury Release Proposed Rules and a Report to Congress regarding Mental...

King & Spalding on

On July 25, 2023, HHS, the Department of Labor, and the Department of the Treasury (the Departments) issued proposed rules (Proposed Rules) and other information regarding health plan and issuer compliance with mental health...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

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

Mental Health Parity Compliance Remains a Key Focus for Federal Agencies

On July 25, 2023, the U.S. Department of Labor (DOL), the U.S. Department of Health and Human Services (HHS), and the U.S. Department of the Treasury released their annual report to the U.S. Congress regarding group health...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

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

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

Seyfarth Shaw LLP

New Guidance on Gag Clause Attestation

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Consolidated Appropriations Act, 2021 (“CAA”) contains a requirement that that group health plans may not have agreements with service providers that would restrict certain information that the plan may...more

Ballard Spahr LLP

Unmuzzled: Time to Attest That No Gags Apply

Ballard Spahr LLP on

Summary - The Departments of Labor, Health and Human Services, and the Treasury have issued guidance on how health plans and insurers may attest to their compliance with the anti-gag rules of the Consolidated...more

Stinson - Benefits Notes Blog

Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting

On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are...more

FordHarrison

Deadline for Prescription Drug and Health Care Spending Reporting

FordHarrison on

The Consolidated Appropriations Act (CAA) adopted a new prescription drug reporting mandate on November 12, 2021. The mandate requires group health plans and group health insurers to submit prescription drug and health care...more

Mintz - Employment Viewpoints

HHS, Treasury and Labor Issue More Guidance on the No Surprises Act

Title I of Division BB of the Consolidated Appropriations Act, 2021 (the “Act”), and interim final rules issued by the Departments of Health and Human Services, Treasury and Labor (the “Departments”) in July 2021 (see our...more

Rivkin Radler LLP

Mental Health Parity – After Years of Failure to Comply, Enforcement is Underway!

Rivkin Radler LLP on

Regulators are now better armed to cite and fine health plans that are not complying with the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008. A recent report to Congress highlights the enforcement work to date...more

Foley & Lardner LLP

Health Plans’ Prior Authorization Rules are under Scrutiny by the DOL for Mental Health Parity Compliance – See the DOL’s Top Five...

Foley & Lardner LLP on

On January 25, 2022, the U.S. Departments of Labor (“DOL”), Treasury, and Health and Human Services (the “Departments”) provided a report (the “Report”) on Mental Health Parity and Addiction Equity Act (“MHPAEA”) compliance...more

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