As a reminder, the deadline for submitting Patient-Centered Outcomes Research Institute (PCORI) fees is July 31. Employers who sponsor self-insured group health plans should report and pay PCORI fees using the most recently...more
By July 31, employers that sponsor self-funded medical plans must report and pay their PCORI fee. By July 31, employers that sponsor calendar-year employee benefit plans that are subject to ERISA must file a Form 5500 (unless...more
On May 21, 2025, the Sixth Circuit revived a company’s lawsuit against Blue Cross Blue Shield of Michigan (BCBSM) for breaching its fiduciary duties under ERISA as a third-party administrator (TPA). The plaintiff company,...more
There has been a recent rise in Employee Retirement Income Security Act of 1974 (ERISA) litigation against third-party administrators (TPAs) and other service providers challenging their management of self-funded health...more
While the Patient-Centered Outcomes Research Initiative (“PCORI”) fee was updated at the turn of the year, the fee is not actually paid until July. For those of you that forgot about the fee, this is your reminder to start...more
If you are a state or local government that sponsors a “self-funded” employee group health plan instead of using an insurance provider, you had previously been allowed to “opt out” of compliance with the following four...more
In the wake of the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization and subsequent state abortion bans, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services issued a...more
In a recent article in Managed Healthcare Executive, Peter Wehrwein examines the trend of self-funding of group health benefits by smaller employers who used to depend mainly or entirely on fully insured programs....more
In a recent On the Subject (available here), we reported on the impact of the final rule (final rule) interpreting Section 1557 of the Affordable Care Act (ACA) on self-funded group health plans that contract with licensed...more
Federal legislative and regulatory activity related to employer-sponsored group health plans shows no signs of slowing, particularly with the issuance of interpretive guidance regarding the transparency and surprise-billing...more
Many employees—and some employers—don’t realize how much companies pay for fully funded health insurance premiums. According to the KFF 2022 Employer Health Benefits Survey, premiums cost an average of $7,911 for single...more
Employees generally know healthcare is expensive, but they often don’t know just how expensive until they’re on COBRA and are shocked at the cost. Companies pay around $23,000 per year for family and $8,000 per year for...more
On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023 (“CAA, 2023”), into law. The CAA, 2023, which is largely a bipartisan spending bill, sunsets provisions of the Public Health Service Act...more
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
Pennsylvania AG Josh Shapiro charged state contractor Glenn O. Hawbaker, Inc. (“Hawbaker”) with four counts of theft relating to Hawbaker’s alleged underpayment of more than $20 million to its employees in violation of the...more
The healthcare industry is rapidly changing, and self-funded employer sponsored health plans have more options to consider when creating solutions for their employees. In today’s episode, Jennifer Mills and Susan Hughes...more
When New York adopted a wage parity law setting minimum wage and benefit levels for home care workers, innovative home health care agency companies created a captive plan structure to meet the benefits requirements. Although...more
Under the new Massachusetts Paid Family Leave Law, M.G.L c. 175M (“MAPFML”), employees and other covered individuals in the Commonwealth will be entitled to a generous set of new paid leave benefits and rights beginning...more
Earlier this year, the Department of Labor issued an information letter explaining ERISA’s authorized representative requirement. Below are some of the takeaways employers may want to consider....more
Seyfarth Synopsis: The Ninth Circuit Court of Appeals recently confirmed that ERISA preempts state insurance law bans on discretionary clauses for self-funded ERISA plans....more
Over the last several years we have seen employers, especially those with self-funded health plans, evolve in their approach to wellness programs. Programs have grown from gathering data – e.g., steps on a pedometer,...more
In a rare display of bipartisanship, Congress voted to eliminate the Affordable Care Act’s separate cap on deductibles that applies to individual and small group insurance products. (These limits never applied to large...more