The Department of Health and Human Services’ (“HHS”) Office for Civil Rights recently published a final rule (the “Final Rule“) which provides additional privacy protections related to the use and disclosure of reproductive health care information. Covered entities (e.g., health plans) and their business associates must comply with all of the provisions of
Annual Limits on Qualified Plans for 2024
On November 1, 2023, the Internal Revenue Service (IRS) released Notice 2023-75, which sets forth the 2024 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. The IRS also announced the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments earlier this year
Preparing for the End of the COVID-19 Emergency Declarations: Part II. Considerations for COVID-19 Vaccine Coverage
As explained in part I of our Preparing for the End of the COVID-19 Emergency Declaration series, the Public Health Emergency (“PHE”) and National Emergency (“NE”) are coming to a close. While the Biden Administration had initially announced its intent to end the NE on May 11, 2023, on April 10, 2023, President Biden signed
Departments Provide Relief for 2020 and 2021 Prescription Drug Reporting
On December 23, 2022, the Departments of Labor, Health and Human Services and Treasury (the “Departments”) issued FAQs providing relief from prescription drug and health care spending reporting requirements. The FAQs are available here: https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-56.
As part of the Consolidated Appropriations Act, 2021, group health plans and issuers must annually report to the Departments
Just in the Nick of Time – Congress Grants Second Extension of CARES Act Telehealth/HSA Relief
Recently Congress passed the Consolidated Appropriations Act of 2023 (“2023 CAA”). Among other things, the 2023 CAA extends, for a second time, the telehealth relief provided under the CARES Act. The CARES Act permitted high deductible health plans (“HDHP”) to provide first-dollar telehealth services or other remote care services. This allowed individuals covered under a
Annual Limits on Qualified Plans for 2023
On October 21, 2022, the Internal Revenue Service (IRS) released Notice 2022-55, which sets forth the 2023 cost-of-living adjustments affecting dollar limits on benefits and contributions for qualified retirement plans. Earlier this year, the health savings account (HSA) and high deductible health plan (HDHP) annual deductible and out-of-pocket expense adjustments were announced in Revenue
Temporary Extension of CARES Act Telehealth/HSA Relief Available
On March 15, 2022, the Consolidated Appropriations Act of 2022 (“2022 CAA”) was signed into law. Among other things, the 2022 CAA temporarily restores the telehealth relief provided under the CARES Act. The CARES Act permitted high deductible health plans (“HDHP”) to provide telehealth services or other remote care services without applying a deductible. This
Agencies Issue Additional Guidance Regarding Over-the-Counter COVID-19 Test Coverage
As indicated in our January 11, 2022 blog post and alert, the Department of Labor, the Department of Health and Human Services, and the Treasury (the “Agencies”) issued FAQs Part 51 on January 10, 2022, requiring group health plans to cover over-the-counter (“OTC”) COVID-19 tests without participant cost-sharing, preauthorization, or medical management. In response
IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA
On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the American Rescue Plan Act of 2021 (ARPA). For more information about the ARPA and COBRA subsidies, see Stinson’s previous blog: American Rescue Plan Act Contains
DOL’s ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law. Under ARPA, certain employees and their dependents who lost group health coverage during the COVID-19 pandemic due to the employee’s involuntary termination (other than for gross misconduct) or reduction of hours are allowed to temporarily receive fully-subsidized COBRA