News & Analysis as of

Department of Labor (DOL) Consolidated Appropriations Act (CAA) Employee Benefits

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

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

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

Jackson Lewis P.C.

Health and Welfare Plans: Recent Topics in Year-End Compliance

Jackson Lewis P.C. on

As we bid farewell to 2024 and look ahead to the new year, we reflect on the many evolving compliance obligations that health and welfare plan sponsors tackle each year. Although this list is by no means exhaustive, it...more

McDermott Will & Schulte

Complying With the ‘Relevant Data’ Requirement Under the Final 2024 Mental Health Parity and Addiction Equity Act: A Proposal for...

McDermott Will & Schulte 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 & Schulte

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

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

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

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

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

Snell & Wilmer on

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

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

Faegre Drinker Biddle & Reath LLP

The SECURE Act 2.0: The Most Impactful Provisions #14 — Automatic Portability for IRA Force-outs

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

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

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

Bass, Berry & Sims PLC

SECURE 2.0 + 1: Retirement Plan Changes and One Notable Health Plan Change

Bass, Berry & Sims PLC on

As widely reported, the president recently signed into law the Consolidated Appropriations Act of 2023 (CAA 2023), a $1.7 trillion omnibus spending bill, which contains significant provisions affecting employer-sponsored...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

McDermott Will & Schulte

Welcome (But Last Minute) Relief for Prescription Drug Reporting Originally Due December 27

McDermott Will & Schulte on

Section 204 of Title II of Division BB of the Consolidated Appropriations Act, 2021 amended the Internal Revenue Code, the Employee Retirement Income Security Act of 1974 and the Public Health Service Act to add rules...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

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