Health Care Reform Dashboard

Health Care Reform Dashboard

Charting Developments with the
Affordable Care Act and Beyond

Health Benefits

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11/02/2021

Upcoming Compliance Deadlines for Health and Welfare Plans

Summary Throughout 2020 and 2021, employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes arising from the COVID-19 pandemic and new health legislation. To comply with these changes, employers may need to work with their vendors, amend their plans, and take other action. In this alert, [&hellip… Continue Reading »
10/06/2021

Keeping Up With No Surprises

Summary Two sets of rules were issued last month by federal agencies as part of the No Surprises Act. The Upshot The proposed rules come into play when an individual receives out-of-network care in at least one of the following situations: in an emergency, when an out-of-network provider furnishes services in connection with care provided [&hellip… Continue Reading »
08/25/2021

Enforcement Delayed Under the New Health Plan Disclosure Requirements

Summary Three federal agencies, the Departments of Labor, Health and Human Services, and Treasury, jointly released new FAQs on August 20, 2021, regarding compliance with new health plan disclosure requirements of the Transparency in Coverage Final Rules (TiCFR), the No Surprises Act, and additional transparency provisions under the Consolidated Appropriations Act (CAA). In the FAQs, [&hellip… Continue Reading »
05/19/2021

IRS Weighs in on ARPA COBRA Subsidy

Summary The IRS issued guidance on a wide range of questions pertaining to the subsidies that employers are required to offer to COBRA qualified beneficiaries under the American Rescue Plan Act. The Upshot The guidance follows up on prior U.S. Department of Labor guidance, is generally consistent with prior IRS guidance, and includes an extensive [&hellip… Continue Reading »
12/09/2020

Year-End COVID-19 Considerations for Health and Welfare Plans

Summary COVID-19 has dominated the agenda for health and welfare benefits in 2020. From suspended deadlines to mid-year election changes to enhanced cost-free coverage, the pandemic has resulted in significant changes to the design and operation of many health and welfare plans. As the year comes to a close, employers should consider whether they have [&hellip… Continue Reading »
07/10/2020

U.S. Supreme Court Upholds Exemption to ACA’s Contraceptive Mandate

In Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania, the Supreme Court this week upheld regulations issued by the U.S. Departments of Treasury, Labor, and Health and Human Services (the Departments) that exempted employers with sincerely held religious beliefs and employers with moral objections from the requirement to provide contraceptive coverage under [&hellip… Continue Reading »
07/26/2019

U.S. District Court Upholds Short-Term Limited Duration Insurance Rule

The U.S. District Court for the District of Columbia upheld a rule that expanded the maximum length of time for short-term, limited duration insurance (STLDI). STLDI is coverage that lasts a limited period of time and is exempt from many of the requirements that apply to plans in the individual health insurance market. Concerned that STLDI [&hellip… Continue Reading »
07/02/2019

Executive Order Aims to Enhance Transparency in Health Care Costs and Quality

On June 24, 2019, President Trump signed Executive Order 13877, Improving Price and Quality Transparency in American Healthcare to Put Patients First. This is the President’s third executive order affecting the health care industry. Executive Order 13813 issued in October 2017, set the regulatory agenda for Association Health Plans, Short-Term Limited-Duration Insurance, and Individual Coverage Health Reimbursement [&hellip… Continue Reading »
04/01/2019

Association Health Plan Regulations Invalidated

The U.S. District Court for the District of Columbia has set aside the most significant portions of the U.S. Department of Labor’s (DOL) regulations on Association Health Plans (AHPs). The court’s ruling invalidates regulatory provisions that sought to broaden the groups of employers that could be treated as if they were a single employer, allowing [&hellip… Continue Reading »
08/03/2018

Final Regulations Expand Availability of Individual Insurance Not Meeting ACA Requirements

The U.S. Departments of the Treasury, Labor, and Health and Human Services have jointly issued final rules modifying the definition of short-term, limited-duration insurance (STLDI). STLDI provides health coverage that is intended to be transitional in nature. It is not regarded as individual health insurance or minimum essential coverage and is exempt from certain Affordable [&hellip… Continue Reading »
01/10/2018

DOL Proposes Expansion of Association Health Plans

Following up on the direction provided by Executive Order 13813, the U.S. Department of Labor (DOL) has issued proposed regulations that would expand the ability of small employers to band together and provide coverage under a single Association Health Plan (AHP). Under the new rules: AHPs may be formed by employers that are engaged in [&hellip… Continue Reading »
11/15/2017

IRS Prepares to Enforce ACA Employer Mandate

The IRS has announced its intent to begin enforcing the employer-shared responsibility provisions (otherwise known as the employer mandate or pay-or-play provisions) of the Affordable Care Act for the 2015 calendar year. The IRS also published a template letter that it will mail to any applicable large employer (ALE) if it determines the ALE owes [&hellip… Continue Reading »
10/19/2017

Developments in the Affordable Care Act

After a brief lull in activity, recent developments are likely to involve all three branches of government in addressing issues under the Affordable Care Act. The Legislature: It is often said that Congress rarely takes action until a crisis needs to be addressed. With the demise of this summer’s repeal and replace effort, initiatives to [&hellip… Continue Reading »
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