"These rules are not new, so it is not clear why there was a need for the [Chief Counsel Memorandum] at this time. The issuance of this CCA might signal that the IRS is beginning to educate auditors on the substantiation rules and the tax consequences of not complying with these rules.... [A frequent question] is whether it is necessary to substantiate very small expenses, such as those in the $5 or less range. Based on this and earlier IRS guidance, the answer from the IRS' perspective is yes."  MORE >>

"Self-insured plan sponsors can satisfy their compliance obligations by completing and filing Form 720, with its accompanying 720-V payment voucher. Although Form 720 is a quarterly return, for PCORI, Form 720 is filed annually only, by July 31. The updated form can be found here, and the PCORI fee reporting can be found in Part II, Line 133."  MORE >>

"[G]roup health plan sponsors should consider ... [w]hether the group health plan will continue to cover out-of-network COVID-19 vaccines at no cost, or at all. Insured plans should reach out to their insurers to confirm what the insurer has decided to cover. Self-insured plans should work with their third party administrators to determine what coverage options are available after the end of the PHE."  MORE >>

"Size is not the determining factor in whether your company should self-fund its health plan.... The only real risk a company with a self-funded health plan takes on is cash flow variability.... Companies that self-fund save money in the long term -- usually 8 -- 10% on average.... Self-funded plans are significantly more flexible -- meaning you can design your plan, decide whether you want to comply with state mandates or not, and carve out portions of your plan to different vendors that specialize in different areas."  MORE >>

"The three biggest PBMs ... control about 80% of prescription drug sales in America ... While serving as middlemen among drugmakers, insurers, and pharmacies, the three corporations also own the highest-grossing specialty drug and mail-order pharmacies.... [T]he complexity and obscurity of their role in the drug marketplace have skeptics wondering whether legislation advancing in the House and Senate will actually help patients or lower prices at the pharmacy counter."  MORE >>

"Over the next five years, primary care will be enhanced to provide more comprehensive care, manage patients, and reduce costs.... Increased demand, general public concern, and more access channels point to a trend that should finally culminate in mental health parity.... Improving maternity care is finally being recognized as a major issue and is rising on the agenda for politicians, insurance plans, and health systems.... Multiple factors are converging to alter behavioral and social factors to improve health outcomes."  MORE >>

"[N]either the DOL nor ERISA defines steps for determining the reasonableness of vendors' fees.... Years spent interpreting ERISA's vague vendor monitoring principle to employers have led to the formulation of five proven compliance action steps. [1] Read the vendor's disclosures.... [2] Verify that vendors adhere to their contracts.... [3] Establish key performance indicators.... [4] At least annually assess and confirm vendors' compensation for reasonableness.... [5] Factor the broad view into vendor management."  MORE >>