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

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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 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

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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

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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

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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

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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

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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

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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

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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

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Reminder for SBCs – Yes, Please!

The Affordable Care Act’s requirement that group health plans provide summaries of benefits and coverage (“SBCs”) to applicants and enrollees at various times is not new.  Nevertheless, because of the steep penalties for noncompliance (i.e., $1,000 per failure with respect … Continue reading

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