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2020 Drug Coupon Rule Under Further Rulemaking

The U.S. Department of Health and Human Services ("HHS") released final regulations relating to benefit and payment parameters for 2020. The regulations state that beginning on or after January 2020, plans and insurers do not have to count the value

Julie Mitchell, Esq. September 3, 2019
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Reporting Primary Prescription Coverage Mandatory January 2020

The Centers for Medicare & Medicaid Services (“CMS”) has issued new guidance on Medicare Secondary Payer (“MSP”) reporting requirements in response to the SUPPORT for Patients and Communities Act enacted on October 24, 2018. Currently, Responsible Reporting Entities (“RREs”) of

Julie Mitchell, Esq. August 27, 2019
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DOL Expands FMLA Leave to Special Education Meetings

A recent opinion letter issued by the U.S. Department of Labor ("DOL") confirmed that parents attending certain school meetings for the benefit of their children are entitled to the protection of the Family Medical Leave Act (“FMLA”) for their absences

Julie Mitchell, Esq. August 25, 2019
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What is a “Functional” Fiduciary?

ERISA’s Fiduciary Duties Understanding the nature of an ERISA benefit-plan-fiduciary is a big deal; naming fiduciaries and identifying "fiduciary-like" decisions is an even bigger one. A recent Fourth Circuit Court of Appeals opinion reminds employers that the types of decisions

Peter Iverson, Esq. August 15, 2019
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