"Prudent plan fiduciaries will establish and adhere to a formal, written policy to ensure compliance with the New Disclosure Rule. Indemnification and limitation of liability provisions in service provider contracts should also be revisited relative to this new rule."  MORE >>

"Health systems are trying to recoup lost revenue and are feeling emboldened to challenge the major health insurance carriers ... Employers have the power to make changes, and with strategic initiatives and partnerships they can truly shape the market in the future.... [1] Master data.... [2] Evaluate quality and cost metrics.... [3] Identify and implement solutions."  MORE >>

"Travel reimbursement programs that are limited to abortion are more likely to catch the eye of regulators in states that take anti-abortion positions.... [E]mployers should consider whether to offer a broad-scope travel reimbursement program for all medical expenses.... [A]ny paid time off policy available only to women for this purpose (i.e., and not made available to accompany a dependent for the same reason) may violate certain sex and/or gender discrimination laws."  MORE >>

"One acknowledged risk of the excepted benefit EAP approach is the potential for a new administration in Washington to alter the current view on what constitutes 'significant medical care' for purposes of the excepted benefit EAP.... An integrated HRA approach would ... limit availability of an abortion travel benefit to employees enrolled in the medical plan. While an excepted benefit HRA could make an abortion travel benefit more broadly available ... the excepted benefit HRA reimbursement limit ... may be less than the actual abortion travel cost in many instances."  MORE >>

"[C]ompared to their December-born counterparts, dependents with January births were more likely to enroll in their parent's plan and enrolled for a longer period of time.... [T]heir parent is more likely to remain with their pre-ACA employer and remain with that employer for longer. Effects are larger for parents approaching early retirement and dependents who are only children."  MORE >>

"Congress's real deadline to avert premium increases and coverage losses is August. That's because most consumers will make 2023 coverage decisions in 2022, and there are substantial operational runways to set insurance rates, update eligibility systems and consumer-facing language to reflect PTC parameters, and calculate enrollees' new eligibility and notify them -- all before the open enrollment period begins November 1, 2022."  MORE >>