By: Ian Morrison & Jules Levenson
Seyfarth Synopsis: The 7th Circuit recently held that insurers and administrators must provide claimants an opportunity to respond to new information relied on for adverse benefit determinations, even if the claim predated the enactment of the relevant regulation.
In Zall v. Standard Ins. Co., 58 F.4th 284
April 11, 2023 Update: On April 10, 2023, President Biden signed legislation which ended the national emergency (NE) immediately. The public health emergency (PHE) is still expected to end on May 11, 2023. The Outbreak Period discussed below will still end on July 10, 2023 (i.e. 60 days after the date previously announced by the
Seyfarth Synopsis: Under a Tri-Agency Proposed Rule, health plans could be required to report information relating to air ambulance services by March 31, 2023. As this proposed deadline approaches, plan sponsors should reach out to their third party administrators to determine what assistance, if any, will be provided relating to these reporting requirements.
Just as
Seyfarth Synopsis: Plans have been scrambling to gather data and work with providers in preparation for the December 27, 2022 deadline to report prescription drug and health care spending information. Just in time for the holidays, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) have issued FAQs related to Prescription Drug
Seyfarth Synopsis: Recently the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued regulations (the “Final Regulations”) which finalized previously proposed relief for furnishing Forms 1095-B and 1095-C to individuals. Notably, the Final Regulations provide a permanent 30-day extension to the due date for furnishing Form 1095-C to individuals. This extension was previously granted in the 2021 final instructions for completing Forms 1094-C and 1095-C for 2021 (see our blog here) issued in December 2021.
Continue Reading Permanent Extension to the ACA Reporting Deadline
Seyfarth Synopsis: The IRS has announced an increase to the applicable dollar amount for determining the Patient-Centered Outcomes Research Institute (“PCORI”) Fee for 2023 as well as other health and welfare limits.
The Affordable Care Act (ACA) established the PCORI to support research on clinical effectiveness. The PCORI is funded in part by fees paid
Seyfarth Synopsis: IRS quietly extends relief for the “family glitch” to calendar year cafeteria plans in unannounced revisions to Notice 2022-41.
In our October Legal Update (available here), we described the publication of final IRS rules fixing the so-called “family glitch” in the availability of a premium tax credit for Health Insurance Exchange (Exchange)
Seyfarth Synopsis: HHS has announced that the COVID-19 Public Health Emergency (PHE) has been extended another 90 days, and will run until January 11, 2023.
Seyfarth Update: On January 11, 2023, HHS announced another extension of the PHE to April 11, 2023.
Seyfarth Update: On January 20,2023, the Biden administration announced that it is
Seyfarth Synopsis: The IRS has announced adjustments decreasing the affordability threshold for plan years beginning in 2023, which may cause employers to have to pay more for ACA compliant coverage in 2023.
The IRS recently released adjustments decreasing the affordability threshold for plan years beginning in 2023 in Revenue Procedure 2022-34.
Under the Affordable
Seyfarth Synopsis: As more employers announce that they cover travel benefits under their medical plans that will allow participants to be reimbursed for certain travel expenses necessary in order to access otherwise covered medical benefits, proponents on the pro-choice and anti-abortion platforms seek ways to support or block those benefits.
In the weeks since the