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About this Blog
Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.Blog Contributors
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High Deductible Health Plan Telehealth Relief, Extended Again!
If you sponsor a high deductible health plan (“HDHP”) and have been tracking telehealth relief, your head may be spinning and rightfully so! There have been various laws and guidance impacting HDHPs and telehealth since 2020 and most recently, new … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
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Group Health Plans Must Provide Free Over-the-Counter COVID-19 Tests Effective January 15, 2022
On January 10, 2022, the Departments of Labor, Health and Human Services, and Treasury (collectively the “Departments”) issued Affordable Care Act FAQs Part 51 which addresses, in relevant part, payment for over-the-counter (“OTC”) COVID-19 testing. Shortly after, on February 4, 2022, the … Continue reading
Group Health Plans Must Provide Free Over-the-Counter COVID-19 Tests Effective January 15, 2022
On January 10, 2022 the Departments of Labor, Health and Human Services, and Treasury issued Affordable Care Act FAQs Part 51 which addresses, in relevant part, payment for over-the-counter (“OTC”) COVID-19 testing. For more information about the OTC COVID-19 testing and its … Continue reading
Posted in Employee Benefits, Health & Welfare Plans
| Tagged covid, FFCRA, Health Care, health plans
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Not All Surprises Are Good – Phase I of the Surprise Billing Rules
On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services, and Department of Labor issued the interim final rule “Requirements Related to Surprise Billing; Part I” (the “IFR”), which is the … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged Department of Labor, ifr, no surprises act, surprise billing
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Wellness Program Incentives – New Year, New EEOC Proposed Rules
For years we have been trying to understand how the EEOC regulates wellness programs. Although we still do not have a complete picture, we are getting closer with the EEOC’s new Notices of Proposed Rulemaking on wellness programs under the … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged ADA, EEOC, medical, regulations, wellness, wellness program
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What is the Fate of ACA? No Answers Yet from the Fifth Circuit.
Background As noted in our previous December 2018 blog post, “Texas Judge Declares the Affordable Care Act Unconstitutional – What’s Next?,” and our October 2019 newsletter, “2019 End of Year Plan Sponsor “To Do” List (Part 1) Health & Welfare,” … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged ACA, DOJ, individual mandate, reform, SCOTUS, Supreme Court
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Must Drug Manufacturer Coupons Count Toward Annual Maximum Out-Of-Pocket Limits? Stay Tuned …
What is the Annual Maximum Out-Of-Pocket Limit (“MOOP”)? MOOP is the most a participant must pay for covered services under a group health plan in a plan year. After a participant spends this amount on deductibles, copayments, and coinsurance, the … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged coupons, HHS, MOOP, NBPP, Notice, out-of-pocket maximum
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Authorized Representatives – Fresh Look at an Old Rule
Earlier this year, the Department of Labor issued an information letter explaining ERISA’s authorized representative requirement. Below are some of the takeaways employers may want to consider. 1. The Authorized Representative Requirement Under ERISA ERISA’s claims procedure regulations expressly give … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged appeals, authorized representative, claims, DOL, ERISA, health plan
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HHS to Start Randomly Selecting Health Plans for HIPAA Compliance – Are You Ready?
The CMS Division of National Standards, on behalf of HHS, is launching the Compliance Review Program (the “Program”) to ensure compliance among covered entities with HIPAA Administrative Simplification rules for electronic health care transactions. HHS will randomly select health plans … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged audit, Breach Notification, CMS, HHS, HIPAA, Privacy, Security
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Wilderness Therapy – Should We Give It Another Look?
1. What is it? Wilderness therapy generally is traditional therapy in an outdoor setting that seeks to treat young adults with behavioral or substance use disorders. Some programs are licensed and accredited and the treatment they provide can be expensive. … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged litigation, Mental Health Parity, NQTL, therapy, wilderness
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