Sarah Raaii
Subscribe to Sarah Raaii's PostsSarah 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.
From ERISA to CAA: How Have Employers’ Fiduciary Responsibilities Changed Over Time?
By Sarah Raaii and Alden Bianchi on Jul 23, 2024
Posted In Employee Benefits, Health and Welfare Plans
Health plan fiduciary issues have taken on increased urgency following a new wave of Employee Retirement Income Security Act class action lawsuits filed by plaintiffs’ firms. Sarah Raaii and Alden Bianchi recently joined the Moving to Value Alliance, a healthcare nonprofit, for a podcast episode focused on how group health plan sponsors and third-party service...
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HHS Final Section 1557 Nondiscrimination Regulations: Gender-Affirming Care and the Role of Carriers Under ASO Arrangements
By Sarah Raaii, Alden Bianchi and Scott Kenkel on Jun 5, 2024
Posted In Employee Benefits, Health and Welfare Plans
On April 26, 2024, the US Department of Health and Human Services (HHS) issued a final rule (press release, fact sheet, FAQs) reinterpreting Section 1557 of the Affordable Care Act, which prohibits discrimination on the basis of race, color, national origin, sex, age or disability, or any combination thereof, in a health program or activity, any part of which...
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OPM Urged to Commit to Protecting IVF in Federal Health Insurance
By Sarah Raaii on May 22, 2024
Posted In Employee Benefits, Health and Welfare Plans
Democratic lawmakers recently sent a letter to the US Office of Personnel Management urging the Biden administration to enhance the Federal Employees Health Benefits Program’s in vitro fertilization coverage. The letter comes as some states have signaled an interest in enforcing personhood rights in treatments involving embryos, according to this Federal Times article. “When you...
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IRS Announces 2025 Limits for Health Savings Accounts, High-Deductible Health Plans and Excepted Benefit HRAs
By Jacob Mattinson, Sarah Raaii and Alden Bianchi 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 Sarah Raaii, Alden Bianchi and Scott Kenkel 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 Sarah Raaii 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 Alden Bianchi and Sarah Raaii 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 Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo 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 Alden Bianchi, Sarah Raaii and Jacob Mattinson 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 Scott Weinstein and Sarah Raaii 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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