With the deadline for revising the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Notice of Privacy Practices set for yesterday, February 16, 2026—which was extended to today because of the federal holiday—the federal government published a revised version
Health Care Reform Dashboard
Charting Developments with the Affordable Care Act and Beyond
The Health Care Reform Dashboard, published by Ballard Spahr LLP, focuses on legal developments and regulatory updates related to health care reform. It covers topics such as changes to health savings accounts (HSAs), Affordable Care Act (ACA) reporting requirements, fiduciary duties in health plan offerings, pharmacy benefit management (PBM) regulations, and enforcement of No Surprises Act provisions. The blog analyzes court decisions, administrative guidance, and legislative changes affecting group health plans, employer obligations, and health insurance market rules. It serves as a resource for understanding the legal landscape impacting health benefits, compliance, and health care policy implementation.
PBM Transparency: Next Steps for Plan Sponsors
The federal government recently delivered back-to-back measures forcing pharmacy benefit managers (PBMs) to be more transparent about their business models. However, with this heightened transparency comes a host of new fiduciary obligations for sponsors of health and welfare benefit plans.…
Mark Your Calendar: HIPAA Deadline on February 16
The Health Insurance Portability and Accountability Act (HIPAA) regulations require updates to the Notice of Privacy Practices that health plan sponsors furnish to plan participants and health care providers furnish to patients. The updates must be made by February 16,…
IRS Touches Up the One Big Beautiful Bill
The Internal Revenue Service (IRS) has provided guidance on the changes made to the rules governing health savings accounts (HSAs) in the One Big Beautiful Bill, which was enacted this summer.
The Upshot
The guidance addresses:
- The retroactive extension of
…
IRS Relief Alleviates Some—But Not All—ACA Reporting Issues
Employers now may have an opportunity to save money and time by posting a Notice of Availability with respect to the reporting required by the Affordable Care Act (ACA) and Forms 1095-B and 1095-C.
The Upshot
- IRS guidance permits employers
…
While Congress Slept: Health Benefit Developments During the Shutdown
Although much of our attention this fall was focused on the government shutdown, health plan sponsors may be interested in several less-publicized developments affecting group health plans.
The Upshot
- Two universities have been accused in lawsuits of breaching their fiduciary
…
Court Upholds Arkansas Pharmacy Benefit Management (PBM) Reporting Requirements
A recent federal district court decision has upheld an Arkansas Insurance Department rule that requires health benefit plans to submit certain pharmacy compensation information to the Department. The court ruled that this reporting requirement is not preempted by ERISA, finding that…
Courts Split on Enforcement of No Surprises Rules
The Fifth Circuit and the Federal District Court of Connecticut have issued conflicting decisions on whether service providers may sue to enforce arbitration awards under the No Surprises Rules in the Consolidated Appropriations Act, 2021. While the Connecticut court found…
The OBBBA’s Impact on Employee Benefits and Executive Compensation
H.R.1—the One Big Beautiful Bill Act (OBBBA)—contains several provisions that directly affect employer-provided benefit programs, primarily health and welfare programs.
The Upshot
The new budget law’s changes to health and welfare benefits include:
- Beginning in 2026, the amount that
…
Mental Health Brake: 2024 MHPAEA Regulations Put on Hold
A recent court filing offers a reprieve to health plan sponsors in their efforts to comply with final regulations issued last year under the Mental Health Parity and Addiction Equity Act (MHPAEA). In a motion to stay proceedings in a…