group health plans Archives - EMPLOYEE BENEFITS BLOG

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

by Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo | Mar 29, 2023 | 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 and Addiction Equity Act (MHPAEA). The end of the NE and the PHE will require modifications to group health plans’ and health insurance issuers’ MHPAEA testing as it relates to financial requirements and quantitative treatment limits. The NE and the PHE also affect the design and operation of some employee assistance plans (EAPs). The NE and the PHE allowed plan sponsors to expand coverage under excepted benefit EAPs in certain respects without risking their status as the Health Insurance Portability and Accountability Act (HIPAA)-excepted benefits. MHPAEA MHPAEA requires that the financial...

Safe Harbor Issued for Reporting Healthcare Prices Under Transparency Rules

by McDermott Will & Emery | May 17, 2022 | Employee Benefits, Health and Welfare Plans

The US Departments of Labor, Health and Human Services, and the Treasury recently released Frequently Asked Questions (FAQs) regarding the implementation of certain reporting provisions of the Affordable Care Act (ACA). The FAQs were released to provide clarity on the required drug price disclosures identified in the Transparency in Coverage final rule (the Rule) issued on October 29, 2020. As described in this SHRM article, employers are responsible for making sure that these disclosures are ready and available. Read more here.

Agencies Issue Final Employer Healthcare Price Transparency Rule

by Jacob Mattinson and Sarah Raaii | Dec 10, 2020 | Employee Benefits, Health and Welfare Plans

On October 29, 2020, the US Departments of Health and Human Services, Labor, and Treasury (collectively, the Departments) issued the Transparency in Coverage final rule (the Rule), along with a fact sheet, setting forth requirements for group health plans and health insurance issuers to disclose cost-sharing information upon request to participants, as well as additional pricing information to the general public. Access the article.

A Momentary Victory for the ACA: Federal Judge Issues a Nationwide Injunction against Trump Administration’s Contraceptive Coverage Carve Outs

by Jacob Mattinson and Megan Mardy | Jan 24, 2019 | Employee Benefits, Health and Welfare Plans

On January 14, 2019, US District Judge Wendy Beetlestone in the US District Court for the Eastern District of Pennsylvania issued a nationwide preliminary injunction blocking the Trump administration’s carveouts to the Affordable Care Act’s (ACA) contraceptive coverage mandate. One day prior, US District Judge Haywood Gilliam in the US District Court for the Northern District of California issued a more limited injunction blocking the same carve outs from taking effect in 13 states plus the District of Columbia. On October 6, 2017, the Trump administration issued rules that are the subject of these two decisions. The rules would have allowed employers to raise religious and moral objections to avoid the ACA’s requirement that contraceptive coverage be provided without cost sharing under their group health plans. Under the ACA, certain contraceptive products and services are included in the list of preventive services that must be covered by most group health...

Fridays with Benefits Webinar | Mental Health Parity and Compliance Complexities

by Jacob Mattinson | May 24, 2018 | Employee Benefits, Health and Welfare Plans

New proposed guidance on mental health parity issued last month spotlights the complexities of these rules. Join us for out next Fridays with Benefits webinar on June 1 as Jacob M. Mattinson and Judith Wethall discuss the impact these rules will have on group health plans and how to determine if your plan complies. Find out about recent litigation and agency enforcement actions. Friday, June 1st, 2018 10:00 – 10:45 am PDT 11:00 – 11:45 am MDT 12:00 – 12:45 pm CDT 1:00 – 1:45 pm EDT Register now.

Government Shutdown Pushes Back Cadillac Tax

by Anthony A. Bongiorno | Jan 24, 2018 | Employee Benefits, Health and Welfare Plans

On January 22, 2018, Congress passed an interim funding bill to end the three-day government shutdown that also pushed back the effective date of the Affordable Care Act’s controversial “Cadillac Tax.” The Cadillac Tax imposes an excise tax on group health plans that provide benefits in excess of certain thresholds. The new legislation pushes the effective date back an additional two years to January 1, 2022.

21st Century Cures Act: Small Employer Changes under the Affordable Care Act

by McDermott Will & Emery | Dec 16, 2016 | Health and Welfare Plans

President Obama has signed the 21st Century Cures Act, Pub. L. No. 114-225 (Dec. 13, 2016). As we previously mentioned, the new legislation permits small employers (those that are not considered applicable large employers under the Affordable Care Act (ACA)) to maintain general-purpose stand-alone Health Reimbursement Arrangements (HRAs) if they do not offer a group health plan to any of their employees. Stand-alone HRAs were not permitted based on ACA guidance. Annual benefits under these new HRAs cannot exceed an indexed maximum of $4,950 per year ($10,000 if family members are covered), must be funded solely by employer contributions (employee contributions are not permitted), and can only be used for the reimbursement of Internal Revenue Code §213(d) medical care expenses.

Implementation Date for New Summary of Benefits and Coverage Template

by Megan Mardy | Mar 23, 2016 | Employment, Health and Welfare Plans

The U.S. Departments of Treasury, Labor, and Health and Human Services (the Departments) recently issued new guidance regarding the intended timeframe for the use of the new summary of benefits and coverage (SBC) template and instructions, an updated uniform glossary and other associated materials. Background The Affordable Care Act (ACA) generally requires group health plans and health insurance issuers offering group or individual health insurance coverage to provide an SBC to participants and beneficiaries. The Departments issued revised final regulations governing the SBC requirement on June 16, 2015, and published a proposed new SBC template on February 26, 2016. Comments on the proposed template and associated documents are due by March 28, 2016. Read the full article.

Agencies Clarify Cost-Sharing Limits Under the Affordable Care Act

by Megan Mardy | Jun 11, 2015 | Health and Welfare Plans

The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively, the Departments) have issued a set of Frequently Asked Questions (FAQs) clarifying the limitations on cost sharing under the Affordable Care Act. Read the full article.

Additional Guidance Issued on Summary of Benefits and Coverage Disclosure Requirements

by McDermott Will & Emery | May 16, 2013 | Health and Welfare Plans

by Amy M. Gordon and Joanna C. Kerpen The U.S. Departments of Labor, Health and Human Services, and the Treasury recently issued new guidance and templates regarding the summary of benefits and coverage requirement under the Patient Protection and Affordable Care Act. To read the full article, click here.

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