Chevron Defense Overturned

You’ve heard about Chevron being overturned . . . let’s get into it from the group health plan administration perspective. 

What do you need to know today and going forward? 

1. What does this mean for benefits professionals, including how group health plans are administered today? 

    • Nothing changed for benefits professionals as of today, July 8, 2024. 
    • However, for human resources professionals that support Texas employers, the effective date of the DOL’s new overtime rule as applied to Texas has been delayed.  
      • For practitioners in employee relations and wage compliance, partner with your experienced employment/wage law counsel for updates on the FLSA delay that may impact your organization. 

2. What does this mean for benefits professionals in the next few weeks? 

      • Watch the ComplianceDashboard blog for tips on how to explain this ruling to executives as it may pertain to group health plan administration in the future.  
      • By effectively communicating how this may impact HHS, EBSA, and OCR interpretations to your executive, if shifts do occur due to court rulings in the impacted district, you will be able to shift with agility, if necessary. 

3. What does this mean for benefits professionals in the next six months

      • There is surely more guidance and changes to come. Ensure that you work with a trusted, experienced professional in employee benefits and compliance, like ComplianceDashboard, to navigate going forward. 
      • There are regulations that may be impacted in the upcoming months, due to several active cases. 

4. What was the Chevron framework? 

      • Chevron previously held that when Congress passes a law that lacks specific implementation guidelines, courts had to give wide leeway to decisions made by the federal agencies (i.e. HHS, EBSA, or the EEOC) charged with interpreting that law. 

5. Now what is going to happen to agency interpretations? 

      • The ruling on Chevron v Natural Resources Defense Council gave courts the authority to determine whether an agency correctly interpreted a federal law enacted by Congress and signed by the President of the United States. 
          • The majority opinion discussed “respect” for agency interpretations on the law going forward. 
        • Going forward, there will have to be interested parties that file actions in court to challenge agency interpretations for them to be overturned. 

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