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Recent Insights

No Surprise Billing Interim Final Regulations, Part 2

3-MINUTE READ On July 1, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury, along with the Office of Personnel Management (collectively, the Departments), issued an interim final rule (IFR) to explain provisions of the No Surprises Act (the Act) that passed as part of sweeping COVID-19 relief legislation signed in December […]

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Webinar: The No Surprises Act Interim Final Rules

Tuesday, August 10, 2021 2:00 p.m. ET / 11:00 a.m. PT Register Now On July 1, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury, along with the Office of Personnel Management (collectively, the “Departments”), issued an interim final rule (IFR) to explain provisions of the No Surprises Act (the Act) that […]

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June Compliance Recap

5-MINUTE READ June 2021 was not a busy month in the benefits industry, largely due to the summer vacation season and the Independence Day holiday. Importantly, however, the U.S. Supreme Court upheld the constitutionality of the Patient Protection and Affordable Care Act (ACA). Additionally, the IRS unveiled a tool to assist families in taking advantage […]

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IRS Issues Draft Form 1095-C

The Internal Revenue Service (IRS) recently issued the 2021 Draft Form 1095-C, which is required to be filed with the IRS by applicable large employers (ALEs), to report the offer of health coverage to employees. New Codes An ALE that offers an individual coverage health reimbursement arrangement (ICHRA) can now use two previously-reserved codes in […]

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No Surprise Billing Interim Final Regulations: Part 1

4-MINUTE READ On July 1, 2021, the U.S. Departments of Health and Human Services, Labor, and Treasury, along with the Office of Personnel Management (collectively, the Departments), issued an interim final rule (IFR) to explain provisions of the No Surprises Act (the Act) that passed as part of sweeping COVID-19 relief legislation signed in December […]

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DOL Requires Disclosure of Audio Recordings under ERISA Claims Procedure

2-MINUTE READ The Department of Labor (DOL) recently issued Information Letter 06-14-2021 in which the DOL opined that audio recordings of a conversation between a participant and plan representative, and transcripts of the recordings, are subject to disclosure during the claims adjudication process under ERISA Section 503. The DOL’s position is not surprising based upon […]

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Webinar: Legal Considerations in Safely Returning to Work

Tuesday, July 13, 2021 2:00 p.m. ET / 11:00 a.m. PT Register Now The COVID-19 pandemic has resulted in workplace closures for over a year. Due to the increase in vaccinations and declining infection rates, many states are lifting stay-at-home and business closure mandates so that the country can return to business as usual. To […]

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IRS Tool for Advance Child Tax Credit

2-MINUTE READ TIME On June 14, 2021, the IRS issued a news release which unveiled an online Non-filer Sign-up tool designed to help eligible families who don’t normally file tax returns register for the monthly Advance Child Tax Credit payments, scheduled to begin July 15. The tool is also designed to help eligible individuals who don’t normally […]

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May Compliance Recap

10-MINUTE READ May 2021 was a somewhat busy month in the benefits industry. The absence of a significant of amount of agency guidance during the summer months is to be expected. However, the IRS finally issued guidance on the temporary 100% COBRA subsidy mandated by the American Plan Rescue Act of 2021 (the ARP), following […]

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BCBSA Antitrust Settlement Classes Eligible for Proceeds

2 MINUTE READ November 5, 2021 is the deadline for filing a claim in connection with the Blue Cross Blue Shield Association (BCBSA) $2.67 billion settlement reached in October 2020. The class action lawsuit was filed more than eight years ago by subscribers seeking injunctive and compensatory relief arising out of BCBSA’s alleged violation of […]

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