News & Analysis as of

Employer Group Health Plans U.S. Treasury Reporting Requirements

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

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

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Verrill on

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...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

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

Foley & Lardner LLP

Group Health Plans Subject to New Prescription Drug and Health Care Spending Reporting Requirements

Foley & Lardner LLP on

Under the Consolidated Appropriations Act, 2021 (the “CAA”), group health plans and health insurance issuers are required to submit certain information related to prescription drug and other health care spending to the...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,...

New Guidance Delays Some Key CAA and Other Health Benefit Effective Dates

New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more

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

Agencies Issue FAQs on Required Comparative Analysis of Nonquantitative Treatment Limitations

The Consolidated Appropriations Act (CAA), 2021 had far-reaching effects on employee benefit plans. One of the more onerous changes introduced by the CAA relates to the Mental Health Parity and Addiction Equity Act of 2008...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 16 of 24): Reporting for, and Clearing Up...

In an earlier post, we reported on a troubling development in the draft 2015 instructions for Forms 1094-B and 1095-B which, if adopted, would have required sponsors of Health Reimbursement Arrangements (“HRA”) to issue...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 15 of 24): Coding Form 1095-C, Part II for...

As we noted in a previous post, the recently issued final 2015 Instructions for Forms 1094-C and 1095-C changed certain of the rules relating to the reporting for offers of COBRA coverage where the COBRA qualifying event...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 7 of 24): Mergers and Acquisitions

When it comes to mergers and acquisitions involving at least one applicable large employer (ALE), the substantive rules governing employer shared responsibility (under Internal Revenue Code § 4980H) and the corresponding...more

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