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OBBBA's Impact on Employee Benefit Plans, Programs, and Arrangements
McDermott Will & Emery 
[Guidance Overview] July 29, 2025 "[P]lan sponsors should consider the following measures ... [1] Reevaluate dependent care FSAs.... [2] Consider retroactively or prospectively reinstating first-dollar telehealth and other remote-care service coverage under HDHPs.... [3] Identify whether to adopt or further explore [direct primary care] arrangements.... [4] Review current or potential employer-provided childcare programs in light of expanded tax credits.... [5] Evaluate and make any required updates to plan documents in light of the OBBBA and any changes adopted." MORE >> |
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