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
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.
Latest from Health Care Reform Dashboard - Page 4
Comprehending the Non-Comprehensive: Proposed Rules Tackle Some Non-Traditional Coverage
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…
Meet me at the Corner of No Surprises and …
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…
COVID-19 Coverage Without a Deductible Ends After 2024
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…
Preventive Care Rules Remain in Place for Now
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…
Reminder: Reporting Requirement for Health Care Costs One Month Away
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…
FAQs Provide Guidance on Preventive Care
Summary
The Departments of Labor, the Treasury, and Health and Human Services have jointly issued FAQs that address the requirement to cover the full cost of certain preventive care services in view of the recent ruling in Braidwood v. Bacerra that invalidated…
Court Invalidates Certain Preventive Care Requirements
Summary
Health plans and insurance policies may no longer be required to cover the full cost of preventive care that carries an A or B rating by the U.S. Preventive Services Task Force (USPSTF), following a recent ruling by a…
Unmuzzled: Time to Attest That No Gags Apply
Summary
The Departments of Labor, Health and Human Services, and the Treasury have issued guidance on how health plans and insurers may attest to their compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA).
The Upshot
- The
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Strike Two: Court Again Invalidates No Surprises Procedure
Summary
The U.S. District Court in the Eastern District of Texas vacated certain provisions of the No Surprises regulations that it found inappropriately placed a “thumb on the scale,” and limited the discretion of arbitrators.
The Upshot
- A district court has again
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