The Departments of Labor (“DOL”), Health and Human Services (“HHS”), and the Treasury (collectively, “the Departments”) recently published mental health parity enforcement guidance, including new […]

On July 20, 2023, the Centers for Medicare & Medicaid Services (“CMS”) and the Departments of Labor (“DOL”) and the Treasury (collectively, “the Departments”) issued a letter to employers, plan sponsors and carriers encouraging that they allow additional time to enroll in employer-sponsored health plans for individuals who have lost Medicaid and Children’s Health Insurance Program (“CHIP”) coverage due to Medicaid resuming normal eligibility and enrollment procedures and operations.

These rules would impact employers offering hospital indemnity and other fixed indemnity insurance. In addition, the guidance suggests additional rulemaking may be forthcoming as it relates to level-funded plans and specific disease-related coverage.

As previously reported, insurance carriers and plan sponsors of group health plans must submit information annually to the Centers of Medicare and Medicaid Services (“CMS”) attesting that their plan(s) do not include prohibited gag clauses. The first attestation is due December 31, 2023.

As a result of the COVID-19 pandemic, high deductible health plans (“HDHPs”) can provide coverage for COVID-19 testing and treatment before the minimum deductible is […]