Summary The U.S. Department of Labor (DOL) has issued a temporary enforcement policy to address frequently asked questions about the requirement for certain service providers to disclose direct and indirect compensation data to group health plan fiduciaries under the Consolidated Appropriations Act (2021) (CAA). The Upshot The CAA’s disclosure requirement applies to entities providing brokerage or consulting services [&hellip… Continue Reading »
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 »
Recent guidance issued jointly by the U.S. Departments of Labor, Health and Human Services, and the Treasury clarifies how the Affordable Care Act’s requirement to provide cost-free coverage for preventive care applies to several types of products and services. In particular, the guidance clarifies that: Coverage for all types of contraception (currently 18 different types are [&hellip… Continue Reading »
In a wide-ranging set of frequently asked questions (FAQs) and other guidance, the U.S. Departments of Labor, Treasury, and Health and Human Services have addressed a number of issues pertaining to the Affordable Care Act (ACA). They include issues pertaining to COBRA and the Children’s Health Insurance Program Reauthorization Act (CHIPRA), annual cost-sharing limits, preventive care, [&hellip… Continue Reading »
The U.S. Department of Health and Human Services has issued final regulations and a set of frequently asked questions and answers establishing standards for the provision of essential health benefits in the individual and small group insurance markets, both inside and outside of an Exchange. In large part, the final rules adopt standards set forth in the proposed regulations [&hellip… Continue Reading »
On February 17, 2012, the U.S. Department of Health and Human Services (HHS) released a set of FAQs concerning the Essential Health Benefits Bulletin it issued on December 16, 2011. The FAQs offer new guidance and raise new questions about the scope of what is considered an essential health benefit (EHB) for purposes of applying [&hellip… Continue Reading »
Continuing the furious pace with which it has been issuing health care reform guidance, the U.S. Department of Health and Human Services (HHS) has indicated that all health reimbursement accounts (HRAs) that were in effect before September 23, 2010, are exempt from the Patient Protection and Affordable Care Act’s prohibition against annual limits for plan [&hellip… Continue Reading »
In a new technical release, the government agencies responsible for implementing various health care reform requirements (the U.S. Departments of Labor, the Treasury, and Health and Human Services) have extended the reprieve that they previously granted with respect to certain rules affecting health benefit claims and appeals. Last year, these agencies announced that they would [&hellip… Continue Reading »
Facing the application of new nondiscrimination rules imposed by national health care reform legislation, insured health plans have been granted a reprieve. According to IRS Notice 2011-1, the government agencies responsible for administering the health care reform law (U.S. Departments of Treasury, Labor, and Health and Human Services) have agreed to delay enforcement of the [&hellip… Continue Reading »
The U.S. Department of the Treasury has revised its previously issued regulations on health plans that are “grandfathered” from certain health care reform requirements. Specifically, a group health plan does not lose its grandfathered status solely due to the issuance of a new health insurance policy, either as a renewal of an existing insurance policy [&hellip… Continue Reading »
The U.S. Departments of Treasury, Labor, and Health and Human Services have released guidance on how employer-sponsored self-funded group health plans can satisfy the new external claims review requirements arising from the federal health care reform legislation. The new guidance, which supplements initial claims review guidance issued by the Departments on July 22, 2010, is [&hellip… Continue Reading »
The recent health care reform legislation requires a group health plan to maintain an internal claim and appeal process that meets certain standards and to provide for an external appeal process. The U.S. Departments of Treasury, Labor, and Health and Human Services have jointly released regulations that address these subjects. Internal Claims and Appeals The [&hellip… Continue Reading »
The U.S. Departments of Treasury, Labor, and Health and Human Services have jointly released regulations that address the preventive health care requirements established by the recent health care reform legislation. The regulations apply to plan years beginning on and after September 23, 2010. For calendar year plans, the rules take effect January 1, 2011. The [&hellip… Continue Reading »
The U.S. Departments of Treasury, Labor, and Health and Human Services have jointly released regulations that address several requirements established by the recent health care reform legislation. Most of the changes addressed by the regulations apply to plan years beginning on and after September 23, 2010. For calendar year plans, the rules take effect January [&hellip… Continue Reading »
The wait is over for the estimated 2.2 million health plans hoping to qualify for grandfathered health plan status under the recently enacted health care reform legislation. Today, the three primary agencies charged with regulating and enforcing the federal government’s health care reform effort (Department of Treasury, Department of Health and Human Services, and Department [&hellip… Continue Reading »
The newly enacted health care reform bill has fueled numerous questions by employers seeking direction on arguably the most important workplace decisions they will make in the next few years. Employers need to understand the issues and recognize the decision points and their ramifications. Jean C. Hemphill and Brian M. Pinheiro have identified frequently asked [&hellip… Continue Reading »
