News & Analysis as of

Disclosure Requirements Health Insurance Department of Labor (DOL)

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

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

Schwabe, Williamson & Wyatt PC

Year-End Compliance Considerations for Employee Benefit Plans

Open enrollment is right around the corner (at least for employers that run calendar-year health benefit plans), so many employers will be updating their benefit communication plans. Though not comprehensive, the following is...more

McDermott Will & Emery

Takeaways from a Recent COBRA Notice Class Action Settlement

Recent years have seen a barrage of class action lawsuits alleging that group health plan continuation coverage election notices, required under the Consolidated Omnibus Budget Reconciliation Act (COBRA), are deficient in one...more

Mitchell, Williams, Selig, Gates & Woodyard,...

National Association of Insurance Commissioners (NAIC) 2022 Summer Meeting Summary

The Mitchell Williams Insurance Regulatory team of lawyers recently attended the National Association of Insurance Commissioners (NAIC) 2022 Summer National Meeting which was held in Portland, Oregon on August 9-13th. We have...more

Fisher Phillips

July 1 Deadline Looming for Health Plan Transparency Rules

Fisher Phillips on

In late 2020, the Departments of Health and Human Services, Labor, and Treasury (the Departments) released Transparency in Coverage (TiC) rules that put several new compliance burdens on group health plan sponsors. The next...more

Jackson Lewis P.C.

Transparency in Coverage Enforcement

Jackson Lewis P.C. on

On April 19, 2022, the Departments of Labor, Health and Human Services, and the Treasury issued additional guidance under the Transparency in Coverage Final Rules issued in 2020. The guidance, FAQs About Affordable Care Act...more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Snell & Wilmer

An Interesting Intersection: No Surprises Act Claims and the New Fee Disclosure Requirements for Group Health Plans

Snell & Wilmer on

As reported in our January 7, 2022 SW Benefits Blog “The DOL Asks and Answers Questions About the New Welfare Plan Fee Disclosure Rules,” group health plans must now comply with the ERISA Section 408(b)(2) disclosure...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

Seyfarth Shaw LLP

Guidance Arrives on Long-Awaited Compensation Disclosures for Group Health Plans

Seyfarth Shaw LLP on

Seyfarth Synopsis: Almost a decade after the 408(b)(2) fee disclosure requirements took effect for retirement plan service providers, Congress finally passed legislation addressing compensation disclosure rules for service...more

Goodwin

HHS, Labor, and Treasury Departments Defer Enforcement of Transparency in Coverage and No Surprises Act Requirements

Goodwin on

The No Surprises Act and Transparency in Coverage final rules go into effect January 1, 2022. Implemented as Titles I and II of Division BB of the Consolidated Appropriations Act, these rules are intended to protect patients...more

Bass, Berry & Sims PLC

First Installment of Surprise Billing Regulations Released

On July 1, the Department of Health and Human Services (HHS), Department of Labor, and Department of the Treasury (Departments) jointly issued interim final rules (IFR) implementing certain aspects of the No Surprises Act...more

Mitchell, Williams, Selig, Gates & Woodyard,...

"No Surprises Act" Compliance Tips For Group Health Plans and Health Insurance Issuers

On July 13th, group health plans and health insurance issuers subject to the Federal No Surprises Act (the “Act”) received the first phase of interim final rules promulgated under the Act (the “Rules”) and issued by the...more

Holland & Knight LLP

HHS Issues Interim Final Rule Implementing Certain Provisions of the No Surprises Act

Holland & Knight LLP on

The U.S. Departments of Health and Human Services (HHS), Labor and Treasury, along with the Office of Personnel Management, on July 1, 2021, issued a much-anticipated Interim Final Rule with Comment Period (IFC) –...more

Faegre Drinker Biddle & Reath LLP

Departments Release FAQs on Implementing the Mental Health and Substance Use Disorder Parity Requirements under the Consolidated...

As described in a recent blog post, the Consolidated Appropriations Act, 2021 amended the Mental Health Parity and Addiction Equity Act (MHPAEA) to require group health plans and health insurance issuers (collectively, “group...more

Fisher Phillips

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

Fisher Phillips on

The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

Mintz - Health Care Viewpoints

Health Plan Transparency Rule: Comment Period Ends This Week

In November 2019, the U.S. Department of Health and Human Services, along with the U.S. Department of Treasury and the U.S. Department of Labor, (collectively, the Departments) released a proposed rule requiring group health...more

Bass, Berry & Sims PLC

Trump Administration Proposes Transparency Rule for Group Health Plans and Insurers

Bass, Berry & Sims PLC on

On November 15, 2019, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the Departments), unveiled a proposed rule (scheduled to be published on November...more

Stinson LLP

Association Health Plans Present Opportunities for Employers

Stinson LLP on

New guidance helps plan sponsors and employers manage and operate AHPs - The Department of Labor (DOL) and Internal Revenue Service (IRS) recently released guidance related to the DOL's June 28th final rule on association...more

Littler

New Administration Orders Freeze of Pending Regulations, Takes Aim at the Affordable Care Act

Littler on

One of the first acts of the new Administration on Inauguration Day was to issue a memorandum putting the brakes—at least temporarily—on federal regulations that have not yet taken effect, and to release an executive order...more

Perkins Coie

Avoiding COBRA’s Bite: Measures to Counter COBRA Class Actions

Perkins Coie on

With the filing of a class action complaint in late 2016 in the U.S. District Court for the Southern District of Florida, Wal-Mart Stores, Inc. became the latest large company accused of failing to provide adequate notices as...more

FordHarrison

What Impact Could Trump's Election Have on Employers?

FordHarrison on

The election is over. The vote is in. Donald Trump will be our 45th President. And, for the first time since 2006 (when the 109th Congress was in session during the Bush administration), come 2017, a Republican President will...more

Proskauer - Employee Benefits & Executive...

Health and Human Services, Labor and Treasury Departments Release New Summary of Benefits and Coverage Templates and Accompanying...

The Departments of Health and Human Services (“HHS”), Labor (“DOL”), and Treasury (the “Departments”) have jointly released final changes to the Summary of Benefits and Coverage (“SBC”) template, the Uniform Glossary, and...more

BCLP

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

BCLP on

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

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