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PODCAST: Williams Mullen's Benefits Companion - Health Plan Transparency Requirements
PODCAST: Williams Mullen's Benefits Companion - Group Health Plan Service Provider Compensation Disclosure Requirements
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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
Employer group health plans must make an annual disclosure of the plan's prescription drug and healthcare spending to the Centers for Medicare & Medicaid Services (CMS). The disclosure, called the Prescription Drug Data...more
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
As we turn the page to 2025, employers and HR professionals are turning their attention to ensuring compliance with the reporting and disclosure requirements of the Affordable Care Act (ACA). ...more
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
Open enrollment season can put a spotlight on the many complex rules applicable to employer-sponsored health and welfare plans. As you announce your benefit offerings for the upcoming plan year and tirelessly work to inform...more
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
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
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
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
Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022....more
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
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
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
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
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 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
...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
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
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
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
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
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
On December 6, 2020, we posted an article titled “RADICAL new transparency rules likely apply to your health plan in one year.” The regulations are a little more than 150 PDF pages long. The following is intended to provide a...more
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