April 12, 2021

Clarifying The CAA’s Mental Health Parity Rules

The government has published a new set of FAQs (FAQ 45) elaborating on the enhanced compliance requirements of  The Consolidated Appropriations Act of 2021 (CAA) relative to the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). The CAA requires the government to be more proactive in its enforcement efforts with respect to non-quantitative… Continue Reading

April 8, 2021

ARPA’s COBRA Subsidy: Part 2: Additional Guidance from the DOL

The Department of Labor (DOL) posted Model COBRA Notices and an accompanying FAQs to “fill in the gaps” on guidance for group health plans and plan administrators regarding the American Rescue Plan Act’s (ARPA’s) 100% COBRA Premium Subsidy (Subsidy) for assistance eligible individuals (AEIs) from April 1, 2021 through September 30, 2021. AEIs are those… Continue Reading

March 19, 2021

COBRA Provisions in the American Rescue Plan Act of 2021 (ARPA)

In addition to providing stimulus checks to many Americans, ARPA includes provisions designed to make it easier for people who have lost their jobs to receive health care continuation coverage under COBRA. THE SCOPE OF THE SUBSIDY A COBRA qualified beneficiary who is an Assistance Eligible Individuals (AEI) can receive COBRA continuation coverage without having… Continue Reading

March 9, 2021

Continuity of Care Requirements in the Consolidated Appropriations Act

The Consolidated Appropriations Act (CAA) includes provisions designed to prevent patients from losing access to an in-network provider (including in-network facilities) while in a course of treatment. Specifically, the Act applies to so-called “continuing care patients” who would lose such access to in-network benefits as a result of: a termination of a provider’s network contract;… Continue Reading

February 19, 2021

New Administration, New Rules

With a new administration comes new rules. Executive actions have put some rules on hold while others remain in force. Watch our Associate General Counsel, Liv Ash, give a quick overview of what this means for group health plans.

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