June 22, 2022


On June 3, 2022, the IRS announced on its “Employee Plans News” website a “pilot” pre-examination compliance program for retirement plans, including 401(k) plans. Beginning this month, the IRS will send a letter to sponsors whose plans have been selected for examination, giving them 90 days in which to review plan documents and operations and… Continue Reading

June 21, 2022

Reminder: Transparency Rule for Welfare Plans Takes Effect July 1, 2022

This blog is a reminder that on July 1, 2022, the federal government will begin enforcement of the Transparency in Coverage (TIC) Rules.  The Rules themselves were effective for plan years beginning on or after January 1, 2022, but enforcement was delayed to allow additional time for compliance. The TIC Rules require non-grandfathered health plans… Continue Reading

April 1, 2022

HIPAA Cybersecurity: Time to Strengthen IT Defenses

The Office of Civil Rights (OCR) released its Q1 2022 Cybersecurity Newsletter March 17. Let’s review OCR’s guidance for HIPAA-Covered Entities (CEs) who house and transmit protected health information (PHI). Note: CE’s aren’t only hospitals and insurers; health plans (Plans) are CEs under HIPAA. Employers who sponsor such Plans typically “perform” actions required by the… Continue Reading

March 14, 2022

CAA of 2022…Whhaaaattt?

Congress recently passed the Consolidated Appropriations Act of 2022.  Readers may remember the Consolidated Appropriations Act of 2021 which included the No Surprises Act and numerous transparency-related provisions that caused (and are continuing to cause) massive upheavals in how health plans and health care providers deliver their products. The 2022 version of the CAA contains… Continue Reading

March 1, 2022

Departments Issue Memo re: TX Court Invalidation of IRD Rule: Updated Guidance Pending

The Departments of Health and Human Services, Labor, and the Treasury (the “Departments”) issued a Memorandum in response to the recent decision of a Texas court invalidating certain portions of the independent dispute resolution (IDR) rule promulgated by the Departments under the No Surprises Act (NSA). NSA’s IDR Process in a Nutshell The NSA requires… Continue Reading

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