C&M Health Law

C&M Health Law

Analysis, commentary, and the latest developments in health care law and policy

Category Archives: Employee Benefits

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DOL, HHS & Treasury Issue Final Rules on ACA Market Reforms

Posted in Employee Benefits, Health Care Reform & ACA, Mental Health Parity
On November 18, 2015, the Departments of Health and Human Services (“HHS”), Labor (“DOL”) and Treasury (collectively, the “Departments”) issued final rules regarding a variety of market reforms under the Affordable Care Act, including grandfathered plans, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent coverage, claims and appeals procedures and patient protections. This rulemaking—which… Continue Reading

DOL, HHS & Treasury Issue Guidance on Cost Sharing and Provider Non-Discrimination Under ACA

Posted in Employee Benefits, ERISA, Health Care Reform & ACA
On May 26, the Departments of Health and Human Services (“HHS”), Labor (“DOL”) and Treasury (collectively, the “Departments”) issued Part XXVII of their FAQs about Affordable Care Act implementation. This latest FAQ provides additional guidance regarding limitations on cost sharing under the ACA, as well as further information and guidance regarding the ACA’s “provider non-discrimination”… Continue Reading

DOL, HHS & Treasury Issue Guidance on Contraceptives and Other Preventive Services under ACA

Posted in Employee Benefits, ERISA, Health Care Reform & ACA
On May 11, the Departments of Health and Human Services (HHS), Labor (DOL) and Treasury (collectively, the “Departments”) issued Part XXVI of their FAQs about Affordable Care Act implementation. This latest FAQ provides additional guidance regarding “first-dollar” coverage of preventive services under the ACA (i.e., the requirement to provide certain preventive services without the imposition… Continue Reading

Proposed EEOC Rules Promise to Bring Some Harmony to Wellness Plan Compliance Efforts

Posted in Employee Benefits, ERISA
Ensuring that wellness plans are legally compliant has been challenging in recent years, with the Equal Employment Opportunity Commission challenging as unlawful certain wellness plan features expressly permitted by the Departments of Labor, Health and Human Services and Treasury (the “Departments”). However, proposed EEOC regulations on the use of incentives under wellness plans promise to… Continue Reading

Study Suggests Many ACA Exchange Plans Violate Federal Parity Laws

Posted in Employee Benefits, Health Care Reform & ACA, Mental Health Parity
According to a new study focusing on consumer information, nearly 25 percent of group health plans provided through Affordable Care Act (“ACA”) exchanges may be violating federal mental-health parity laws. The study was led by associate professor Colleen Barry of the Johns Hopkins Bloomberg School of Public Health, and is published in the current issue… Continue Reading

IRS Provides First Guidance on ACA’s ‘Cadillac Tax’

Posted in Employee Benefits, ERISA, Health Care Reform & ACA
On February 23, the Department of Treasury and the Internal Revenue Service (collectively, the “Agencies”) issued Notice 2015-16, the first piece of guidance on the Affordable Care Act’s “Cadillac Tax.” The Cadillac Tax is a 40 percent excise tax that is imposed on high-cost health plans under Section 4980I of the Internal Revenue Code (Code),… Continue Reading

DOL, HHS & Treasury Issue Additional Guidance Regarding Excepted Benefits

Posted in Employee Benefits, ERISA, Health Care Reform & ACA, HIPAA & Privacy, Mental Health Parity
On February 13, the Departments of Health and Human Services (“HHS”), Labor (“DOL”) and Treasury (collectively, the “Departments”) issued Part XXIII of their FAQs about Affordable Care Act implementation. This latest FAQ provides additional guidance regarding “excepted benefits,” i.e., benefits that are exempt from the portability rules under HIPAA as well as various requirements under… Continue Reading

HHS, Labor, and Treasury Issue Flurry of Rulemakings and Guidance on Employee Benefits to Close 2014 with a Bang

Posted in Employee Benefits, Health Care Reform & ACA, Mental Health Parity
The last several weeks of 2014 brought with them a flurry of guidance from the Departments of Health and Human Services (“HHS”), Labor (“DOL”) and Treasury (collectively, the “Departments”) regarding group-health plan employee benefits issues, including issues under the Affordable Care Act (“ACA”), the Employee Retirement Income Security Act (“ERISA”) and the Mental Health Parity… Continue Reading