News & Analysis as of

Department of Health and Human Services (HHS) Employer Group Health Plans Prescription Drugs

Morgan Lewis - ML Benefits

Executive Order Targets Prescription Drug Pricing: Potential Impact on Group Health Plans

President Donald Trump issued an executive order (EO) on May 12, 2025 to address the high cost of prescription drugs in the United States with the goal of ensuring Americans have access to most-favored-nation (MFN) pricing,...more

Lathrop GPM

Administration Issues Cross-Agency Guidance Targeting Health Care Pricing and Focusing on Hospitals and Health Plans

Lathrop GPM on

On May 22, 2025, the U.S. Department of Health and Human Services, Department of Treasury and Department of Labor (the “Agencies”) announced new steps intended to “strengthen healthcare price transparency.” ...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

Venable LLP

February 29 Deadlines for Group Health Plans

Venable LLP on

February 29 brings two annual deadlines for employers that sponsor a group health plan for their employees. Medicare Part D—Creditable Coverage Disclosure to CMS - An employer with a group health plan that provides...more

Ballard Spahr LLP

HHS Announces Temporary Copay Accumulator Non-Enforcement Policy

Ballard Spahr LLP on

The United States Department of Health and Human Services (HHS) has filed court pleadings stating that it does not intend to initiate enforcement actions against plans that maintain copay accumulator programs....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

Foley & Lardner LLP

RxDC Reporting Relief for Plans, Issuers, and Plan Service Providers

Foley & Lardner LLP on

On December 23, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) provided welcome relief in the form of an FAQ regarding the Prescription Drug Data Collection (RxDC)...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

Holland & Hart - The Benefits Dial

I Want a New Drug…Prescription Drug Data Collection Reporting is Due December 27th

Plan sponsors are ultimately responsible for compliance with the Prescription Drug Data Collection (RxDC) required reporting for their group health plans—and there’s no time to waste since the reporting is due by December 27,...more

Jackson Lewis P.C.

December 27, 2022, Deadline for Mandatory Rx Data Collection Reporting

Jackson Lewis P.C. on

As group health plan sponsors, employers are responsible for ensuring compliance with the prescription drug data collection (RxDC) reporting requirements added to ERISA by the Consolidated Appropriations Act of 2021 (CAA). ...more

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

Making a List, Checking It Twice: Year-End Guidance on Drug Cost Reporting

Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data - but no more time to comply with - daunting prescription drug cost reporting requirements in the...more

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

Consolidated Appropriations Act Requirements to Increase Health Plan Transparency

The Consolidated Appropriations Act (CAA), 2021, which was signed into law December 27, 2020, includes provisions designed to increase transparency in employee health benefit plans in four key areas. Removal of Gag Clauses...more

McDermott Will & Schulte

Agencies Issue Final Employer Healthcare Price Transparency Rule

McDermott Will & Schulte on

On October 29, 2020, the US Departments of Health and Human Services, Labor and Treasury (collectively, the Departments) issued the Transparency in Coverage final rule (the Rule), along with a fact sheet, setting forth...more

Snell & Wilmer

Must Drug Manufacturer Coupons Count Toward Annual Maximum Out-Of-Pocket Limits? Stay Tuned …

Snell & Wilmer on

What is the Annual Maximum Out-Of-Pocket Limit (“MOOP”)? MOOP is the most a participant must pay for covered services under a group health plan in a plan year. After a participant spends this amount on deductibles,...more

Foley & Lardner LLP

Is an Employer’s Health Plan Required to Count the Value of Drug Manufacturer Coupons Towards an Employee’s Out-of-Pocket Maximum?

Foley & Lardner LLP on

Background. These days, almost all employer-sponsored group health plans require an employee (and any dependents) covered under the plan (each are referred to as a “member”) to pay “out-of-pocket” for covered expenses in the...more

Roetzel & Andress

Florida Medical Marijuana Law Will Take Effect January 2017

Roetzel & Andress on

Florida voters passed a new medical marijuana law, Amendment 2, on November 8, 2016. Florida joins 27 other states, the District of Columbia, Puerto Rico, and Guam in allowing public medical marijuana programs. The new law...more

McGuireWoods LLP

Washington Healthcare Update

McGuireWoods LLP on

Bicameral Bill Introduced to Provide HHS Authority to Reject Proposed Insurance Rates - Before Congress left for its Columbus Day recess, Rep. Jan Schakowsky (D-IL) and Sen. Diane Feinstein (D-CA) introduced the Health...more

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