News & Analysis as of

Consolidated Appropriations Act (CAA) Regulatory Requirements

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

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

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

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

Maynard Nexsen

Tri-Agency FAQ Provides Updated Guidance Regarding Compliance with the Gag Clause Prohibition

Maynard Nexsen on

On January 14, 2024, the Departments of Labor, Health and Human Services, and the Office of Personnel Management (the “Departments”) jointly released the FAQs About Consolidated Appropriations Act, 2021 Implementation Part 69...more

Ballard Spahr LLP

Surprise, Surprise! No Surprise Billing Regulations Upheld

Ballard Spahr LLP on

The Fifth Circuit Court of Appeals recently upheld regulations defining the qualifying payment amount (QPA). The QPA is a key factor in determining how much individuals and health plans must pay out-of-network providers in...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

Polsinelli

SECURE 2.0: Retirement Plan Rules Get a Makeover!

Polsinelli on

SECURE 2.0, which was signed into law on December 29, 2022 as part of the larger Consolidated Appropriations Act, is the most wide-sweeping retirement plan legislation enacted in more than a decade. It contains a myriad of...more

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

SECURE 2.0 Retirement Legislation Has Arrived in Style and Is Here to Stay: Top 10 Contribution-Related Provisions

After months of suspense and intrigue on whether SECURE 2.0 would make it to the finish line and become law, the U.S. Congress ended the suspense by attaching SECURE 2.0 to the Consolidated Appropriations Act, 2023 funding...more

Faegre Drinker Biddle & Reath LLP

The SECURE Act 2.0: The Most Impactful Provisions (#3–Extension of RMD Start Ages)

The President signed the Consolidated Appropriations Act, which included SECURE Act 2.0, on December 29, 2022. SECURE Act 2.0 has over 90 provisions, some major and some minor; some mandatory and some optional; some...more

Nelson Mullins Riley & Scarborough LLP

First Major Overhaul of Cosmetics Regulation Since FDR Administration

As part of the Consolidated Appropriations Act, 2023, President Biden signed into law the Modernization of Cosmetics Regulation Act of 2022 (“MoCRA”). This is the first major reform of cosmetics regulation since the Federal...more

Perkins Coie

Congress Passes Major Update to Federal Cosmetics Regulation

Perkins Coie on

Buried within the thousands of pages of the Consolidated Appropriations Act of 2023 is the most significant statutory expansion to the U.S. Food and Drug Administration’s (FDA) authority over cosmetics since 1938...more

Holland & Hart - Health Law Blog

Prepare for the End of the Public Health Emergency: Compliance Concerns

For nearly three years, federal and state agencies have waived or relaxed regulatory requirements and expanded reimbursement for services due to the COVID-19 public health emergency (PHE), but the signs indicate that the...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

Proskauer - Health Care Law Brief

The Surprises Continue: The Biden Administration Delays Implementation of Certain Provisions of the No Surprises Act and...

In a FAQ published on August 20, 2021, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) significantly delayed implementation of statutory requirements on surprise billing...more

McAfee & Taft

New health plan guidance regarding transparency regulations and last year’s budget act

McAfee & Taft on

Late last Friday afternoon, the Departments of Labor, Health and Human Services, and the Treasury issued some new frequently asked questions (FAQs) regarding implementation of the transparency in coverage (TIC) regulations...more

Hogan Lovells

No Surprises Act prohibits balance billing, creates arbitration process for out-of-network providers

Hogan Lovells on

Effective January 1, 2022, the “No Surprises Act” signed into U.S. law as part of H.R. 133, “Consolidated Appropriations Act, 2021,” implicates (1) emergency services provided by non-participating providers at participating...more

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

Consolidated Appropriations Act Underscores Mental Health Parity Compliance

The Consolidated Appropriations Act (CAA), 2021, enacted late in 2020, imposes a new requirement on group health plans to ensure compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA). Unlike many of the...more

Nossaman LLP

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

Nossaman LLP on

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

Holland & Knight LLP

Reauthorized PHMSA Seems Set for Renewed Environmental Emphasis Under Biden

Holland & Knight LLP on

The Pipeline and Hazardous Material Safety Administration (PHMSA) states that its mission "is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are...more

Morgan Lewis

Hospice: Consolidated Appropriations Act Revamps Medicare Survey and Certification Process

Morgan Lewis on

Modifications also include public disclosure of accreditation organization survey information and intermediate civil penalty remedies for noncompliance. The Consolidated Appropriations Act, 2021 (Pub. L. 116-260), signed into...more

Morgan Lewis - ML Benefits

Mental Health Parity Transparence: Consolidated Appropriations Act, 2021

As we addressed in our recent LawFlash covering the Consolidated Appropriations Act, 2021 (Act), the Act includes several requirements to enhance group health plan transparency. One provision we wanted to further highlight...more

Cohen & Gresser LLP

Pulling Back the Curtain: Congress Establishes a Beneficial Ownership Registry for U.S. and Foreign Businesses

Cohen & Gresser LLP on

On January 1, 2021, Congress overrode President Trump’s veto, passing into law the annual National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). ...more

Littler

DOL Issues Proposed Regulations on Handling Tips and the “80/20 Rule”

Littler on

Over a year after Congress amended the Fair Labor Standards Act (FLSA) to clarify tip ownership questions, the U.S. Department of Labor (DOL) finally published a Notice of Proposed Rulemaking on October 8, 2019, with proposed...more

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