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Employer Group Health Plans Disclosure Requirements Consolidated Appropriations Act (CAA)

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

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

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

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

Dorsey & Whitney LLP

Courts Address Participant Standing to Challenge Fees and Payments Received by Group Health Plan Service Providers

Dorsey & Whitney LLP on

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

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Health Plan Transparency Requirements

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt is joined by his colleague, Allison Carlon, who helps us better understand what employers need to know about the Consolidations Appropriations Act...more

Williams Mullen

Health Plan Transparency Requirements are Effective Now

Williams Mullen on

The Consolidated Appropriations Act, 2021 (“CAA” or the “Act”) includes several transparency requirements for health plans. Some of these requirements are already in effect for plan years beginning on or after January 1,...more

Perkins Coie

Contractual Considerations for Self-Funded Group Health Plan Sponsors in 2022

Perkins Coie on

In our January 2022 update, we discussed new federal requirements that group health plans should pay close attention to in 2022. The sponsor of a self-funded plan will need to work closely with its legal counsel, benefits...more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Group Health Plan Service Provider Compensation Disclosure Requirements

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses the group health plan broker and consultant compensation disclosure requirements under the Consolidated Appropriations Act and what you...more

Laner Muchin, Ltd.

New Employer Group Health Plan Compliance Obligations for 2022

Laner Muchin, Ltd. on

With each new year, new legal obligations for employers sponsoring group health plans seem to arrive. This article provides a brief overview and reminder of some of the new key requirements for 2022, many of which we have...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

Mintz - Employment Viewpoints

Broker and Consultant Compensation Disclosures of General Agent Commissions Under the Consolidated Appropriations Act, 2021

In two previous posts, we reported on the rules enacted in Section 202, Division BB of the Consolidated Appropriations Act, 2021 (the “Act”) requiring the disclosure of direct and indirect compensation paid to brokers and...more

McAfee & Taft

New health plan disclosure requirements should bring more transparency

McAfee & Taft on

Ten years ago, the U.S. Department of Labor (DOL) published a final regulation under the Employee Retirement Income Security Act of 1974 (ERISA) that required retirement plan service providers to disclose information about...more

Mintz - Employment Viewpoints

Department of Labor Issues Advice on Broker and Consultant Compensation Disclosures Under the Consolidated Appropriations Act,...

In Field Assistance Bulletin 2021-03, the Department of Labor (the “Department”) announced a temporary enforcement policy relating to the rules enacted in Division BB of the Consolidated Appropriations Act, 2021 (the “Act”)...more

Mintz - Employment Viewpoints

Broker and Consultant Disclosures to Group Health Plans under Division BB of the Consolidated Appropriations Act, 2021

Division BB of the Consolidated Appropriations Act, 2021 (“Act”) broadly addresses surprise medical billing and health plan transparency. This post focuses on Section 202 of Division BB (the “Provision”), which establishes...more

Foley & Lardner LLP

Employer Checklist for New Health Plan Price Transparency Rules and CAA

Foley & Lardner LLP on

The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...more

Fisher Phillips

Federal Departments Shed Light on Upcoming Health Plan Disclosure Requirements

Fisher Phillips on

A collection of federal agencies recently released guidance to assist group plan health sponsors navigate upcoming disclosure obligations. On November 17, the Internal Revenue Service, the U.S. Department of Labor, and the...more

Foley & Lardner LLP

The Consolidated Appropriations Act’s Compensation Disclosure Provisions from a Carrier and Plan Service Provider Perspective

Foley & Lardner LLP on

...The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) sets forth new compensation disclosure requirements that apply to brokers and consultants with respect to both fully-insured and self-insured group health...more

Verrill

You Are Here: A Mall Directory for Healthcare Transparency Requirements

Verrill on

The old adage “you can’t get where you’re going unless you know where you are” has never seemed more true than when applied to the current mélange of healthcare transparency guidance. Fortunately, a fading relic from...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...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

Holland & Hart - The Benefits Dial

Are You Ready to Provide Your MHPAEA Disclosure?

We previously blogged about the new Mental Health Parity and Addiction Equity Act (MHPAEA) reporting and disclosure requirements established by the Consolidated Appropriation Act, 2021 (CAA). As a refresher, employers and...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

Genova Burns LLC

New Disclosure Requirements Service Brokers and Consultants of Group Health Plans

Genova Burns LLC on

Buried in the Consolidated Appropriations Act of 2021 (the “Act”), which is most known for its $2.3 trillion spending bill that combines $900 billion in stimulus relief for the COVID-19 pandemic, are important new rules...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

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