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.

Preparing for the End of the COVID-19 Emergency: High-Deductible Health Plans and Health Savings Accounts


By , , and on May 3, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration originally 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 prior article for more information). Although the end date of the NE was subsequently advanced to April 10, 2023, by Congressional resolution, the US Departments of Labor, Health and Human...

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Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers


By , , and on Apr 5, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration has announced its intention 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 March 29, 2023, the US Departments of Labor, Health and Human Services, and Treasury (the Departments) issued a set of Frequently Asked...

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Mental Health Parity, Quantitative Treatment Limitations, Employee Assistance Plans and the End of the COVID-19 Emergency


By , , and on Mar 29, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

The Biden administration has announced its intention 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). Among other things: The NE and the PHE modified the rules governing financial requirements and quantitative treatment limitations under the Mental Health Parity...

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Telehealth and the End of the COVID-19 Emergency


By , , and on Mar 22, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration has 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 prior article for more information). In response to the COVID-19 pandemic, lawmakers and agencies made legislative and regulatory changes to expand access to telehealth services for individuals. This article explores...

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Coverage of COVID-19 Vaccines and the End of the COVID-19 Emergency


By , , and on Mar 15, 2023
Posted In Employee Benefits, Health and Welfare Plans

Since the Biden administration announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023, a topic of great debate has been the requirement and the coverage of COVID-19 vaccines. As of March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act has...

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Coverage of COVID-19 Testing and the End of the COVID-19 Emergency


By , , and on Mar 8, 2023
Posted In Employee Benefits, Health and Welfare Plans

A key feature of the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) was the government’s ability to provide access and coverage of COVID-19 tests. This resulted in overlapping legislation targeted at providing tests to benefit plan participants for free. With the end of the NE and PHE set for May 11,...

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How Employers Need to Prepare for the End of the COVID Public Health Emergency and National Emergency


By , , and on Mar 2, 2023
Posted In Employee Benefits, Health and Welfare Plans

On January 30, 2023, the Biden administration announced its intention to make final extensions of both the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) through May 11, 2023, at which point both will end. These emergency declarations have been in place for nearly three years and have enabled the government to...

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Proposed Universal Contraceptive Coverage in Response to Roe Reversal


By and on Feb 14, 2023
Posted In Employee Benefits, Health and Welfare Plans

The US Departments of Health and Human Services, Labor and Treasury (the Departments) recently issued a proposed rule to eliminate a moral exemption to the Affordable Care Act (ACA) contraceptive mandate and establish an “individual contraceptive arrangement” to permit individuals to obtain contraceptive services at no cost in instances in which their employer does not offer...

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No Surprises Act and Three Takeaways on Surprise Billing


By and on Feb 8, 2023
Posted In Employee Benefits, Health and Welfare Plans

The No Surprises Act (NSA) provides federal protections against surprise billing with respect to emergency services, non-emergency items or services furnished by out-of-network providers at certain in-network healthcare facilities, and air ambulance services furnished by out-of-network providers of air ambulance services. The NSA also establishes that certain federal agencies publish information quarterly about the Federal...

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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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