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Employers navigating the complexities of the Mental Health Parity and Addiction Equity Act ("MHPAEA") may find themselves questioning the true impact of the federal government's recently issued nonenforcement policy. This...more
With the HIPAA Security Rule set to undergo a massive overhaul to boost cybersecurity protections, PEOs need to take note. After all, as stewards of worksite employee and client company data – and as sponsors of group health...more
Seyfarth Synopsis: On September 9, 2024, the Departments of the Treasury, Labor, and Health and Human Services (the “Departments”) released highly anticipated Final Rules under the Mental Health Parity and Addiction Equity...more
On Monday, September 9, 2024, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued their final rule regarding the nonquantitative treatment limitation (NQTL) comparative analysis...more
The Consolidated Appropriations Act, 2021 (CAA) added a requirement for health plans to document their compliance with nonquantitative treatment limitations (NQTLs) under the Mental Health Parity and Addiction Equity Act...more
Now you know. It could not be any clearer to employers that compliance with the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) will be a—maybe the—top health and welfare benefit priority for federal...more
Plan sponsors, insurers, and third-party administrators should pay close attention to the new guidance to facilitate health plan compliance with complex nonquantitative treatment limitation comparative analyses requirements....more
Seyfarth Synopsis: Fresh on the heels of the IRS Chief Counsel Memorandum on wellness and indemnity products, discussed in our prior post here, the agencies have weighed in with more formal and more expansive guidance...more
The US Departments of Health and Human Services, Labor and Treasury (the Departments) recently issued a proposed rule (the proposed rule) to eliminate a moral exemption to the Affordable Care Act (ACA) contraceptive mandate...more
This year, Foley’s Health Benefits Practice has released multiple alerts on several of the new group health plan requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage...more
Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...more
The Department of Treasury recently issued proposed regulations to alter the rules for how individuals can get a premium tax credit (PTC) to help pay for Marketplace health coverage starting in 2023. The new rules would base...more
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
For years we have been trying to understand how the EEOC regulates wellness programs. Although we still do not have a complete picture, we are getting closer with the EEOC’s new Notices of Proposed Rulemaking on wellness...more
On January 7, 2021, the Equal Employment Opportunity Commission (EEOC) issued proposed guidance regarding employer-sponsored wellness programs and the level of incentives employers may offer employees who participate in these...more
The Departments of Labor (DOL), Health and Human Services (HHS), and Treasury have issued a proposed rule for grandfathered group health plans under the Affordable Care Act (ACA). The proposed rule provides greater...more
In April 2019, the Department of Health and Human Services (HHS) released guidance indicating that a health plan must include the value of financial assistance received from a drug manufacturer (often referred to as a...more
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
On November 15, 2019, the Federal Government issued two rules: one in final form and one in proposed form, both designed to increase price transparency in health care. The rules follow on the Executive Order announced by...more
On November 15, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Agencies”) issued a proposed "Transparency in Coverage" rule that would require most...more
Employer-sponsored health plans and health insurers may be required to post online - and to provide participants upon request - a range of pricing and cost-sharing information beginning in 2021. Proposed Affordable Care...more
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
On November 15, the Trump Administration released a final rule requiring hospitals to publicly disclose hospital charges, including negotiated prices with third-party payers by January 1, 2021. We outline key considerations...more
As we previously reported, on June 13, the Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) issued a coordinated set of final regulations (“final rules”) permitting employers...more
Health Reimbursement Arrangements (or “HRAs”) are employer-funded, account-based group health plans, which are used to reimburse certain medical expenses incurred by eligible employees, their spouses, and their dependents....more