"The IRS Office of Chief Counsel has issued Memorandum Number 202317020 to explain the substantiation rules for claims made under health and dependent care FSAs by means of six commonly encountered factual situations, in five of which it concludes that the plan is not a cafeteria plan and the reimbursement is not shielded from income and employment taxes."  MORE >>

"It has been almost a year since the US Supreme Court ... returned the question of abortion to the states, resulting in a proliferation of legislation across the country banning, restricting, expanding, or protecting access to abortion.... Employers will need to continue monitoring this area closely to ensure that their policies and benefit plans comply with state and federal requirements."  MORE >>

"In contrast to the current PBM registration process, the TPA licensure process is much more extensive and involves the submission of comprehensive information that will allow the OIR to evaluate a PBM's finances and assess the background and suitability of the PBM's officers, directors, and owners."  MORE >>

"If HHS finalizes the Proposed Rule as written, HIPAA-covered entities ... and business associates must update their privacy policies and procedures, security standards, notices of privacy practices (NPP), authorization and disclosure forms, and business associate agreements, among other documents, to reflect the modifications required by the rulemaking."  MORE >>

"[O]rganizations can ... modernize their wellness programs by taking advantage of new offerings that meet their participants' needs: [1] Set goals.... [2] Identify what's important to your people.... [3] Inventory existing offerings.... [4] Consider a phased-in approach to new program components.... [5] Define measurable outcomes."  MORE >>

"Health care providers are increasingly taking financial risk in their contracts with health insurance companies and, in turn, health insurance companies are becoming more involved in the delivery of care. As each group begins to take on certain characteristics and responsibilities of the other, it is important that they understand the scope of the laws and rules applicable to them."  MORE >>

"[F]ocusing primarily on costs will lead [CMS] into a thicket of implementation challenges and perverse incentives for industry.... The [Inflation Reduction Act's] stipulation that CMS use comparative clinical effectiveness is a step in the right direction but only a partial solution ... The solution [the authors] recommend is to measure a technology's value in terms of health improvements to patients and then use this quantity to set MFP."  MORE >>