The Consolidated Appropriations Act of 2022, which was signed March 15, again permits first-dollar coverage for telehealth services without jeopardizing health savings account (HSA) eligibility, effective April 1, 2022, through December 31, 2022.
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EXAMINING A RANGE OF EMPLOYEE BENEFITS
AND EXECUTIVE COMPENSATION ISSUES
AND EXECUTIVE COMPENSATION ISSUES
In the case of Texas Medical Ass'n, et al. v. US Department of Health and Human Services, et al., the US District Court for the Eastern District of Texas on February 23 invalidated portions of the second interim final rule (IFR) issued by the Departments of Health and Human Services, Labor, and the Treasury (the Departments) under the No Surprises Act.
The Department of Labor (Department) issued Field Assistance Bulletin No. 2021-03 (FAB) on December 30, 2021, announcing a temporary enforcement policy for group health plan service provider disclosures under ERISA Section 408(b)(2)(B).
At the end of each fiscal year, the US Department of Labor’s (DOL’s) Employee Benefits Security Administration (EBSA) compiles the monetary results it obtained through various initiatives meant to ensure compliance with the Employee Retirement Income Security Act (ERISA).
Recent LawFlashes from the employee benefits practice include IRS FAQs: A Potential Shield for Taxpayers—Not a Sword for the Service, A Survival Guide to DOL Group Health Plan Mental Health Parity Audits, and ERISA Fiduciaries: DOL Proposed Rule Signals More Ease for ESG Investing.
The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy for up to six months, from April 1, 2021 through September 30, 2021, for Assistance Eligible Individuals (AEIs) as defined under the guidance. Our prior blog posts, DOL Issues ARPA COBRA Subsidy Model Notices and FAQs and IRS Provides Second Round of FAQs on COBRA Subsidies, provide more information about the ARPA COBRA subsidy and the associated notice requirements.
As we get closer to the September 30 expiration date of the COBRA premium subsidy provided under the American Rescue Plan Act (ARPA), the IRS has issued a second set of FAQs in Notice 2021-46 (Notice) to supplement its prior guidance and provide some specific answers to questions that remained unanswered. The first set of IRS FAQs were provided under Notice 2021-31, which we summarized in our previous LawFlash.
On July 19, the US Departments of Labor, Health and Human Services, and Treasury (the Departments) issued Part 47 of their frequently asked questions (FAQs) about Affordable Care Act (ACA) implementation. There are three new FAQs, all of which pertain to coverage of pre-exposure prophylaxis (PrEP) under Section 2713 of the Public Health Service Act (PHS Act). PrEP is an antiretroviral medication for individuals at high risk of contracting human immunodeficiency virus (HIV).
Addressing what they call the four major “crises” facing the nation—COVID-19, the economy, climate, and inequity—US President Joseph Biden and Vice President Kamala Harris have consistently framed many of their most important executive actions and policy proposals as attempts to prioritize one or more of these four policy concerns. Read our LawFlash for a recap of some of the more wide-reaching and impactful (or in some cases, potentially impactful) executive orders, legislative actions, policy proposals, and other developments during the first 100 days of the Biden-Harris administration.
As we described in our March 15, 2021 LawFlash, the American Rescue Plan Act of 2021 (ARPA) includes a 100% COBRA premium subsidy for any employee or dependent who is a COBRA qualified beneficiary (or will become one) resulting from an involuntary termination of employment or a reduction of hours (referred to as an Eligible Individual).