Sarah Raaii

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Sarah G. Raaii focuses her practice on employee benefits and matters related to health care reform, data privacy and HIPAA compliance, executive compensation, and health and welfare, cafeteria, 401(k), 403(b) and pension plans. Read Sarah Raaii's full bio.

IRS Announces 2025 Limits for Health Savings Accounts, High-Deductible Health Plans and Excepted Benefit HRAs


By , and on May 9, 2024
Posted In Employee Benefits, Health and Welfare Plans

The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2024-25) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and excepted benefit health reimbursement arrangements (HRAs) for 2025. All of the dollar limits currently in effect for 2024 will change for 2025, with the exception of one...

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Gender-Affirming Benefits: Best Practices for Group Health Plans


By , and on Mar 5, 2024
Posted In Employee Benefits, Health and Welfare Plans

Group health plan sponsors, third-party administrators and other health plan service providers must navigate a shifting legal landscape as they determine how to offer gender-affirming benefits, including whether − and to what extent − group health plans must cover gender-affirming medical or surgical treatments, especially regarding minors. In this On the Subject, we discuss recent...

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States’ Rights, Trans Protections Collide at Fourth Circuit


By on Oct 24, 2023
Posted In Employee Benefits, Health and Welfare Plans

The US Circuit Court of Appeals for the Fourth Circuit recently heard two cases from North Carolina and West Virginia state-run health plans that challenge lower court decisions on coverage exclusions for gender dysphoria treatments. According to this Law360 article, the cases could determine how much health plans can restrict access to gender-affirming care. McDermott...

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New MHPAEA Guidance Regarding NQTLs: Network Access and Composition


By and on Oct 5, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

Federal regulators recently announced new mental health parity proposed rules that may add significant new compliance burdens for health plan sponsors, insurers and service providers. The proposed rules may also impact the operation of health plans. A Technical Release accompanied the rules that further explains and invites comment on certain provisions of the proposed rules...

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IRS Opines on the Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policies


By , , and on Aug 10, 2023
Posted In Employee Benefits, Health and Welfare Plans

In light of recent Internal Revenue Service (IRS) guidance, employers should carefully examine any supplemental health plan, program or arrangement (which may or may not claim to leverage fixed indemnity insurance) that promises substantial payroll tax savings. In a legal advice memorandum, the IRS’s Office of Chief Counsel addressed and rejected the claimed tax treatment...

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Treasury, DOL and HHS Issue Landmark Mental Health Parity Proposed Rule


By , and on Aug 8, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

The US Departments of the Treasury, Labor, and Health and Human Services (the Departments) recently issued much-anticipated proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) to better ensure that health plans allow access to mental health or substance use disorder benefits as easily as medical or surgical benefits. The proposed regulations...

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Putting Employee Wellness Programs to Work


By and on Jul 19, 2023
Posted In Digital Health, Employee Benefits, Health and Welfare Plans

What are the opportunities and challenges of digital health wellness programs? In a recent discussion, McDermott Partners Scott A. Weinstein and Sarah G. Raaii discussed a wide range of issues, including accessibility to employees, navigating the health plan regulatory landscape, budgetary constraints and the reality of rising healthcare costs. Read more here.

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IRS Issues Reminder that Claims Under Health and Dependent Care FSAs Must Be Substantiated


By , , and on Jun 1, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Internal Revenue Service (IRS) recently issued a Chief Counsel Advice memorandum to remind sponsors of health and dependent care flexible spending arrangements (FSAs) about their responsibility to adequately substantiate claims in order to receive favorable tax treatment under Section 125 of the Internal Revenue Code (the Code). The IRS emphasizes that the standards for...

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Preparing for the End of the COVID-19 Emergency: Deadline Tolling


By , , and on May 18, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April 10, 2023, President Biden signed a resolution moving up the end of the NE to April 10, 2023 (the PHE ended...

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IRS Announces 2024 Limits for Health Savings Accounts, High-Deductible Health Plans and Excepted Benefit HRAs


By and on May 17, 2023
Posted In Employee Benefits, Health and Welfare Plans

Recently, the Internal Revenue Service (IRS) announced (See Revenue Procedure 2023-23) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and excepted benefit health reimbursement arrangements (HRAs) for 2024. All of the dollar limits currently in effect for 2023 will change for 2024, with the exception of one limit....

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