Employers and their benefit administrators have more detail and a more convenient way to submit “top 50” lists and other data—but no more time to comply with—daunting prescription drug cost reporting requirements in the Consolidated Appropriations Act, 2021 (CAA), under new interim final regulations.
Articles Discussing General Topics In Employee Benefits.
The CAA Transparency Rules Will Let Plans and Participants Know. The Department of Labor, Health and Human Services, and the IRS (collectively the Departments) recently released the Interim Final Rules with a request for Comment (IFC), Prescription Drug and Health Care Spending. These rules implement Section 204, Title II, another
Holiday season and the end of the year are both quickly approaching, and with the turning of the calendar from 2021 to 2022 come several employee benefit plan amendment deadlines and implementation requirements. Some of these changes are optional for plan sponsors to adopt so now is a good time
The Federal Trade Commission (“FTC”) recently issued an important policy statement to health apps and other connected devices that collect or use consumers’ health information. The FTC’s policy statement effectively clarified the position that health apps and related connected devices are subject to the Health Breach Notification Rule (“the Rule”),
As the year draws to a close, it is helpful for employers to pause to evaluate employee benefit plan amendment deadlines and other crucial fourth-quarter considerations, including: More…
The U.S. Department of Labor, U.S. Department of Health and Human Services, and U.S. Department of the Treasury recently issued regulatory guidance on the requirement that health plans cover pre-exposure prophylaxis (PrEP) treatment—“a comprehensive intervention comprised of antiretroviral medication and essential support services”—on a first-dollar basis for individuals at high
New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly—but only slightly—more manageable heading into 2022. Most importantly, the frequently asked questions (FAQ) guidance delays several of the most challenging 2021 and 2022 compliance requirements under the Consolidated
An employer’s permanent cessation of contributions to a multiemployer pension plan can trigger withdrawal liability. This liability may reach affiliated trades or businesses with sufficient common ownership to be under “common control” with the employer. The affiliates would be jointly and severally liable for withdrawal liability incurred and unpaid by
The American Institute of Certified Public Accountants (AICPA) issued a new audit standard for employee benefit plans in July 2019. The new standard is commonly referred to as SAS 136, but its official name is “Statement on Auditing Standards (SAS) No. 136, Forming an Opinion and Reporting on Financial Statements
Participants in dependent care assistance programs (DCAPs) will get the best of both worlds (at least in 2021) under new guidance from the Internal Revenue Service (IRS).
The Trump-era proclamation that would have kept immigrants who could not provide evidence of health insurance within 30 days of coming to the United States has been revoked by President Joe Biden. The move is in accordance with his prior executive order directed at “restoring faith” in the immigration system
The Consolidated Appropriations Act (CAA), 2021 had far-reaching effects on employee benefit plans. One of the more onerous changes introduced by the CAA relates to the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). MHPAEA requires that group health plans offering mental health and substance use disorder benefits
Health care startups in need of specialized guidance often seek consulting services from physicians. While the startup may compensate the physician with a standard hourly, weekly, or monthly rate, more cash conscious ventures may instead offer to compensate the physician with stock options. Such a compensation arrangement presents an undeniable
You didn’t know it was a thing? Or maybe, like most, you just lost track of what day it is? Or maybe it ranks somewhere behind New Beer’s Eve (the day before the end of prohibition) and National Tartan Day, both of which are most certainly things and also fall
A federal court in New Jersey recently applied the arbitrary and capricious standard of review for a denial of benefits claim despite the enactment of an anti-discretionary statute in Minnesota, which governed the benefit plan policy. Hocheiser v. Liberty Mut. Ins. Co., 2021 U.S. Dist. LEXIS 32154 (D.N.J. Feb.