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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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What’s Old Is New Again: HHS Proposes to Reinstate and Expand Transgender Nondiscrimination Rules
Since it was enacted in 2010, Section 1557 of the Affordable Care Act (“Section 1557”) has prohibited discrimination in covered health programs and activities on the basis of race, color, national origin, age, disability, or sex. As we have previously … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 1557, ACA, biden, health program, HHS, nondiscrimination, NPRM, Obama, transgender, Trump
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Federal Agencies Issue Guidance After Dobbs Ruling
In response to the Supreme Court’s ruling in Dobbs v. Jackson Women’s Health Organization, the U.S. Department of Health and Human Services (“HHS”) Secretary Xavier Becerra directed HHS agencies to act within their power to protect the rights of patients … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform, HIPAA
| Tagged abortion, CMS, dobbs, HHS, OCR, roe, wade
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An Interesting Intersection: No Surprises Act Claims and the New Fee Disclosure Requirements for Group Health Plans
As reported in our January 7, 2022 SW Benefits Blog “The DOL Asks and Answers Questions About the New Welfare Plan Fee Disclosure Rules,” group health plans must now comply with the ERISA Section 408(b)(2) disclosure requirements. The CAA amended … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged DOL, fee disclosure, Group health plans, no surprises act, NSA, texas medical, to do list, TPA
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Departments Provide Some Relief to Health Plan Sponsors Facing Looming Year-End Deadlines
Year-end is always a scramble for health plan sponsors as they go through renewal and open enrollment. This year was looking to be worse than normal given the impending deadlines for complying with the transparency in coverage regulations (“TiC”) and … Continue reading
Posted in Employee Benefits, Health Care Reform
| Tagged ACA, CAA, deadlines, health and welfare, transparency in coverage
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Better Late Than Never: IRS Issues Guidance Clarifying COBRA Premium Subsidy Rules
S&W Insight: The IRS clarified several trailing issues with respect to COBRA premium subsidies under the American Rescue Plan Act, including extended election periods, eligibility for other coverage, and rules about allocating premium credits among employers. In addition, a notice … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged american rescue plan, ARPA, COBRA, cobra premium, IRS, notice requirement, subsidy
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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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In Case You Missed It – Key 2021 Employee Benefits Topics
This year is off to a fast start and plan sponsors might find their heads spinning as they try to keep track of rapidly developing employee benefits legislation and guidance. We periodically consolidate key newsletters and blog posts to help … Continue reading
Posted in Employee Benefits, Executive Compensation, Health & Welfare Plans, Health Care Reform, Qualified Retirement Plans
| Tagged COBRA, Consolidated Appropriations Act, multiemployer plan, wellness program
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Credit Where Credit Is Due: IRS Offers Long-Sought Guidance on Employer Retention Credit Program
As we previously reported, the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”) provided for an employee retention credit (“ERC”) designed to encourage employers to retain workers during the COVID-19 crisis. In general, the ERC permits eligible employers … Continue reading
Posted in Employee Benefits, Executive Compensation, Health & Welfare Plans, Health Care Reform, Qualified Retirement Plans
| Tagged CAA, CARES Act, eligible employer, employee retention credit, ERC, paycheck protection program, PPP, Qualified wages
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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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Free COVID-19 Vaccine and Testing Update
On November 30, Moderna announced that it is seeking FDA authorization for its COVID-19 vaccine. In addition, on November 17 the FDA issued an emergency use authorization for the first COVID-19 diagnostic test for self-testing at home. With these recent … Continue reading
Posted in Health & Welfare Plans, Health Care Reform
| Tagged covid, covid-19, fda, health plans, moderna, testing, vaccines
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