Summary
The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy.
The Upshot
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Summary
Employers taking advantage of copay accumulator programs now face unexpected administrative complications following a recent federal court decision.
The Upshot
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Summary
The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed analysis of how a health plan’s…
Summary
On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008…
Summary
By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into on or after the date that…
The Departments of Labor, Health and Human Services, and the Treasury have published a set of proposed rules that impose new limits on two types of benefits: short-term limited-duration insurance (STLDI) and fixed indemnity coverage.
STLDI
STLDI is a form…
Summary
The Departments of Labor, Health and Human Services, and the Treasury have issued guidance that coordinates application of the No Surprise Billing rules under the Consolidated Appropriations Act, 2021, with the cost-sharing limits under the Affordable Care Act and…
The Internal Revenue Service (IRS) has issued new guidance, Notice 2023-37, which states that for plan years ending after December 31, 2024, HSA-compatible high-deductible health plans (HDHPs) will no longer be permitted to cover COVID-19 testing and treatment before…
The Fifth Circuit Court of Appeals has stayed the broad application of a district court decision that would have invalidated a number of preventive care requirements under the Affordable Care Act. As a result, health plans, other than those directly…
Health plan sponsors and health insurers will need to report prescription drug and other health plan costs (RxDC reporting) for 2022 by June 1, 2023. Unlike the RxDC reporting requirements for 2020 and 2021, this deadline is not expected to…
