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.

Prescription Drug Data Reporting: What the “Good Faith Compliance” Extension Really Means for Self-Funded Group Health Plans


By , and on Jan 11, 2023
Posted In Employee Benefits, Executive Compensation, Health and Welfare Plans, Retirement Plans

We recently reported on an FAQ issued December 23, 2022 (FAQ About Affordable Care Act and Consolidated Appropriations Act, 2021 Implementation Part 56) by the US Departments of Labor, Health and Human Services and the Treasury (collectively, the Departments). The FAQ provides limited, albeit welcome, relief by extending the time for reporting information under the prescription drug data...

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IRS Issues Final Regulations Extending ACA Information Reporting Deadlines, Clarifies Additional ACA Issues


By , and on Jan 4, 2023
Posted In Employee Benefits, Health and Welfare Plans

The IRS finalized regulations concerning information reporting of health insurance coverage for Code Sections 5000A, 6055 and 6056. The regulations provide an automatic deadline extension for filing ACA forms and an alternate method for providing ACA forms to certain individuals, among other changes. Access the full article. 

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Omnibus Bill Extends Medicare Telehealth Flexibilities and HDHP Telehealth Safe Harbor


By , , , , , , , and on Dec 28, 2022
Posted In Digital Health, Employee Benefits, Health and Welfare Plans

On December 23, 2022, US Congress approved a year-end omnibus legislative package, Consolidated Appropriations Act, 2023 (CAA 2023), which consists of all 12 fiscal year 2023 appropriations bills and numerous other provisions, including health policy changes. The healthcare provisions in this omnibus package extend key Medicare telehealth flexibilities and the temporary telehealth safe harbor for...

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Employers Seek Clarity on Reproductive Healthcare Benefits Litigation Following EEOC Commissioner Filing


By and on Nov 28, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans

Following the US Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, many employers extended travel benefits to women residing in states where abortion or reproductive health procedures may now be unlawful. Recently, US Equal Employment Opportunity Commission (EEOC) Commissioner Andrea Lucas filed a Commissioner’s Charge against at least three companies alleging that doing so...

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Legal Risks Loom For Employers Protecting Abortion Access


By on Nov 8, 2022
Posted In Employee Benefits, Health and Welfare Plans

US employers are taking steps to provide abortion access to workers despite threats from anti-abortion activists and conservative lawmakers. In this Law360 article, McDermott’s Sarah Raaii said that “we’re certainly continuing to monitor” threats against employers. “And we’re now in the position — really an unprecedented position for employers — of having to potentially look at 50...

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How Employers, Insurers Are Coping with Abortion After Dobbs


By on Oct 4, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans

The US Supreme Court’s ruling overturning Roe v. Wade has created more complexity to the country’s patchwork of abortion laws. In this Managed Healthcare Executive article, McDermott’s Sarah Raaii offers perspective about how insurers are navigating healthcare plans state-by-state. Access the article.

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How the Overturning of Roe v. Wade May Affect US Employer Benefits Plans


By on Sep 22, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans

The US Supreme Court’s decision to overturn Roe v. Wade has led to a flurry of confusion and questions from employers. In this Benefits Canada article, McDermott’s Sarah Raaii explains how some states are imposing criminal penalties for anyone who assists with abortion within their borders. “If a court determines state abortion restrictions are generally...

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Want to Provide Abortion Travel Benefits at Your Company? Here’s How to Protect Employees


By on Sep 1, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans

How can companies provide abortion travel benefits to their workers without disclosing sensitive medical information? In this Corporate Counsel article, McDermott’s Sarah Raaii provides insight into how the Health Insurance Portability and Accountability Act (HIPAA) and the Employee Retirement Income Security Act (ERISA) offer protections for workers seeking reproductive healthcare services. “The most common way...

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What Should GCs Know About the Abortion Landscape?


By on Aug 19, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans

What should company general counsels (GCs) know about abortion trigger bans, the Health Insurance Portability and Accountability Act (HIPAA) and how not to break the law in light of the new abortion landscape in the United States? In this MedCity News article, McDermott’s Sarah Raaii offers insight into how companies can protect abortion access for...

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How Can Employers Protect Workers Who Seek Abortion Care?


By and on Aug 17, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans

As US states seek to reduce abortion access in the wake of the overturning of Roe v. Wade, how can employers protect workers who seek abortion care? In this Fortune article, McDermott’s David Gacioch, Sarah Raaii and Ellen Bronchetti offer insight into what the US Supreme Court’s decision means for employee healthcare data, employee benefits...

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