News & Analysis as of

Consolidated Appropriations Act (CAA) Health Insurance Employer Group Health Plans

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

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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

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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

Alston & Bird on

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

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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

Verrill

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

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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

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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

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

Genova Burns LLC

Heads Up To Group Health Plans: December 31 Gag Clause Attestation Deadline Approaches

Genova Burns LLC on

The Consolidated Appropriations Act of 2021 prohibits group health plans from agreeing to avoid making certain disclosures of provider-specific cost or quality-of-care information. This is referred to as the gag clause...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

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

Morgan Lewis - ML Benefits

First Gag Clause Attestations Due From Group Health Plans by December 31

The Consolidated Appropriations Act, 2021 (CAA), requires group health plans and insurers to annually attest that they are in compliance with the gag clause prohibition under the CAA. The first attestation is due no later...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

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

Warner Norcross + Judd

Preparing for Health Plan Anti-Gag Clause Attestation

Although the end of the year seems far away, employers should start preparing for the anti-gag clause attestations for their group health plans that are due December 31. Namely, employers need to determine who is completing...more

Jackson Lewis P.C.

What Employers Need to Know about the Mental Health Parity Proposed Regulations

Jackson Lewis P.C. on

On July 25, 2023, the tri-agencies of the Departments of Treasury, Labor, and Health and Human Services (the Departments) issued a compendium of guidance designed to facilitate compliance with the Nonquantitative Treatment...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

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

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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

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