Marietta Memorial Hospital Employee Benefit Plan v. DaVita
Posted on July 15, 2022 at 2:59 pm
Supreme Court allows Reduced Reimbursement Rates for Outpatient Dialysis On June 21, 2022, the Supreme Court handed down a decision in Marietta Memorial Hospital Employee Benefit Plan v. DaVita. Justice Kavanaugh, writing for the 7-2 majority, held that the Medicare Secondary Payer rules do not prevent an employee benefit plan from limiting reimbursements for outpatient […]Machine Readable Network and Out of Network Rate Files Enforcement Begins July 1, 2022
Posted on July 1, 2022 at 2:36 pm
The Transparency in Coverage Final Rules (“the TiC Final Rules”) apply to non-grandfathered group health plans and health insurance issuers offering non-grandfathered coverage in the group and individual markets. The rules require the disclosure of information (in machine readable file format) regarding in-network provider rates, out-of-network allowed amounts, and negotiated rates for covered prescription drugs […]
COBRA Premium Assistance Expiration Notice
Posted on September 15, 2021 at 4:12 pm
As the COBRA subsidy period comes to an end on September 30, 2021, plans are required to send a notice 15 to 45 days before an assistance eligible individual’s (“AEIs”) subsidy ends. For AEIs whose subsidy period will end on September 30th, notices must be sent no later than September 15th. The notice must describe: […]ICHRA Subject to ACA Reporting
Posted on September 8, 2021 at 9:51 am
An Individual Coverage Health Reimbursement Arrangement (“ICHRA”) became an available option for employers beginning January 1, 2020. An ICHRA is available to employers of any size to reimburse employees for individual health care coverage (i.e., health coverage bought through the Marketplace, private insurance, or Medicare Part A and B or C coverage), subject to certain […]“Long COVID” to Qualify as ADA Disability
Posted on August 9, 2021 at 9:00 am
Recent guidance released by the Department of Health and Human Services and the Justice Departments’ Civil Rights Division (“Joint Guidance”) confirms that people who continue to experience COVID symptoms months after first being infected may qualify as disabled under the Americans with Disabilities Act (ADA). Anyone who has had COVID-19, even where the initial illness […]Now Available – COBRA Subsidy Model Notices and Q&As
Posted on April 8, 2021 at 3:39 pm
The American Rescue Plan Act of 2021 (“ARPA”) subsidizes the full COBRA premium for Assistance Eligible Individuals (“AEIs”) for six months between April 1, 2021 through September 30, 2021. To be eligible for this premium assistance, the AEIs must: MUST have a COBRA qualifying event that is a reduction in hours or an involuntary termination […]Health Plan Administration Amid COVID-19 Disaster Relief Extensions – Employee Benefit Security Administration Disaster Relief Notice
Posted on March 8, 2021 at 3:26 pm
The Department of Labor issued Notice 2021-01 on February 26, 2021 to address the expiration of the extension of certain benefit deadlines that expired on February 28, 2021. See the summary of Notice 2020-01 at the end of this blog for more information. Notice 2021-01 Notice 2021-01 confirms that the guiding principle for administering employee […]No Surprises Act
Posted on March 2, 2021 at 4:13 pm
The No Surprises Act 2021 is set to take effect for health plan years beginning on or after January 1, 2022. This legislation expands restrictions on charging health care plan holders out-of-network rates for certain services and includes many medical plan changes and requirements, some of which are listed below. No Surprise Medical Billing- amending […]Transparency Reporting Requirements under the CAA
Posted on February 22, 2021 at 1:36 pm
The Consolidated Appropriations Act outlines new transparency requirements for covered service providers as it relates to ERISA group health plans. The Act requires covered service providers, i.e., brokers and consultants to include certain disclosures regarding the receipt of direct and indirect compensation in contracts for services entered, extended, or renewed on or after December 27, […]