CAA #5: Disclosure of Direct and Indirect Compensation to Brokers and Consultants
Background ERISA requires contracts between a health plan and its service providers to be “reasonable.” One element of a contract’s “reasonableness” is the price of […]
EBSA Issues Guidance on COBRA Extensions Related to COVID-19
If the President declares a national disaster, language within ERISA and the Internal Revenue Code permits the Secretaries of the Departments of Labor and Treasure […]
New Administration, New Rules
With a new administration comes new rules. Executive actions have put some rules on hold while others remain in force. Watch our Associate General Counsel, […]
CAA #4: A Prohibition on Gag Clauses
The Consolidated Appropriations Act (CAA) prohibits health plans from entering into contracts that would restrict the plan from: Offering provider-specific cost or quality of care […]
CAA #3: Strengthening Mental Health and Substance Abuse Parity Rules
The Consolidated Appropriations Act (CAA) included provisions designed to strengthen the rules for group health plans to impose Nonquantitative Treatment Limitations (NQTLs) on coverage for […]
Advance Explanation of Benefits: the 411
What is it? An Advance Explanation of Benefits (AEOB) starts with the obligation of a health care provider to furnish a patient with an advance […]
CAA #2: Removing the Element of Surprise: the Consolidated Appropriations Act’s Guidelines for Group Health Plans
CAA NO SURPRISES BLOG The Consolidated Appropriations Act of 2021 (CAA) contained many provisions that directly affect employer sponsored group health plans. In this blog, […]
401(k) Plans: They’re Back! Required Minimum Distributions Resume for 2021
The Coronavirus Aid, Relief, and Economic Security Act of 2020 (“CARES Act”) contained a number of provisions directly relating to 401(k) retirement plans. (See our […]
New Law Encourages Compliance with Recognized Security Practice
The penalties for failing to observe HIPAA’s security rules can be severe. Recent legislation may cushion the impact of those penalties for covered entities making […]