News & Analysis as of

U.S. Treasury Department of Labor (DOL) Compliance

Holland & Hart - The Benefits Dial

No Shoes, No Shirt, No Problems… But Nonenforcement Policy Doesn’t Make Mental Health Parity Compliance Optional

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently announced a nonenforcement policy with respect to the 2024 Mental Health Parity and Addiction Equity Act (“MHPAEA”) regulations or...more

Snell & Wilmer

2024 End-of-Year Plan Sponsor “To Do” List (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 SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...more

Foley & Lardner LLP

Final Mental Health Parity Rules – Top Five Changes to the Status Quo

Foley & Lardner LLP on

The Mental Health Parity and Addiction Equity Act and its implementing regulations and guidance (MHPAEA) prohibit health insurance policies and group health plans that cover mental health and substance use disorder (MH/SUD)...more

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

ACA-Required Coverage of Contraceptive Care Remains Agency Focus

Once again, the U.S. Departments of Labor, Health and Human Services, and the Treasury have issued guidance on the Affordable Care Act’s (ACA) required coverage of contraception without cost sharing, clarifying the permitted...more

Faegre Drinker Biddle & Reath LLP

Reminder: Gag Clause Attestations Due by Year-End

The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more

King & Spalding

IRS Proposed Regulations and DOL Guidance Clarify Certain Aspects of the Prevailing Wage and Apprenticeship Requirements

King & Spalding on

The U.S. Department of Treasury (“Treasury”) and IRS issued proposed regulations (“Proposed Regulations”) on August 29, 2023, regarding increased credit or deduction amounts available under the Inflation Reduction Act of 2022...more

Holland & Hart - The Benefits Dial

Better Hide the Wine … Employer Considerations as the DOL Doubles Down on Mental Health Parity Compliance in New Proposed...

The Department of Labor (DOL), the Department of Health and Human Services (HHS), and the Department of Treasury (collectively, the Departments) recently issued proposed Mental Health Parity and Addiction Equity Act (MHPAEA)...more

King & Spalding

HHS, the Department of Labor, and the Department of the Treasury Release Proposed Rules and a Report to Congress regarding Mental...

King & Spalding on

On July 25, 2023, HHS, the Department of Labor, and the Department of the Treasury (the Departments) issued proposed rules (Proposed Rules) and other information regarding health plan and issuer compliance with mental health...more

Snell & Wilmer

Five Facts About the Annual Gag Clause Prohibition Compliance Attestation

Snell & Wilmer on

Effective December 27, 2020, the Consolidated Appropriations Act, 2021 (“CAA”), as part of its transparency in health care protections, prohibits group health plans and issuers from entering into agreements that directly or...more

Proskauer - Employee Benefits & Executive...

Preventive Care in a Post-Braidwood World: Agencies Release Guidance on Preventive Services Coverage Requirements

The Departments of Labor, Treasury, and Health and Human Services (the “Departments”) recently released guidance for group health plans on required preventive services coverage. The guidance was issued in response to a...more

Proskauer - Employee Benefits & Executive...

Now Live: Tri-Agencies Release Guidance for Group Health Plan “No Gag Clause” Attestations

On February 23, 2023, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued new guidance (in the form of FAQs) implementing the No Surprises Act’s prohibition on “gag clauses” in...more

Sheppard Mullin Richter & Hampton LLP

Tri-Agencies Report MHPAEA Compliance Lacking, But Don’t Name and Shame Plans and Issuers . . . Yet

On January 25, the U.S. Department of Labor (DOL), Department of Health and Human Services (HHS), and the Treasury (collectively the Tri-Agencies) published the first annual report on group health plans’ and health insurance...more

Verrill

Self-Insured Group Health Plan Sponsors: Action Steps to Mitigate Risk Under the Mental Health Parity and Addiction Equity Act

Verrill on

The Mental Health Parity and Addiction Equity Act (“MHPAEA”) provisions of the Consolidated Appropriations Act, 2021 (“CAA”) introduced a requirement that group health plans and insurance providers offering both medical and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

"No Surprises Act" Compliance Tips For Group Health Plans and Health Insurance Issuers

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

Sheppard Mullin Richter & Hampton LLP

The Clock is Ticking on MHPAEA Compliance

State and federal regulators, Congress, and the plaintiffs’ bar are increasingly focused on compliance with the Mental Health Parity and Addiction Equity Act (MHPEA), particularly given the opioid epidemic and COVID-19’s...more

Franczek P.C.

Employee Benefits Alert - July 2015

Franczek P.C. on

Major Revisions to Qualified Plan Determination Letter Process Announced - Effective January 1, 2017, the staggered five-year determination letter remedial amendment cycles for individually designed plans will be...more

Proskauer - Employee Benefits & Executive...

Agencies Issue Final Regulations on the Summary of Benefits and Coverage (SBC) Requirements

As promised in the FAQ issued on March 30, 2015, the U.S. Departments of the Treasury, Labor and Health and Human Services (the Departments) have issued final regulations regarding the summary of benefits and coverage (SBC)...more

Davis Wright Tremaine LLP

Does Your Wellness Plan Need a (Legal) Check-Up?

Wellness plans must comply with complex final regulations that were issued last year by the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”). To help plans from falling off...more

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