"Overall, the Proposed Rule seems focused on the effects of various coverage options on the stability of the risk pools (and premiums) in the individual and small group markets and consumer protection against deceptive or misleading marketing, which is consistent with the Biden Administration's January 28, 2021 Executive Order directing federal agencies to protect and strengthen the [ACA]."  MORE >>

"Consistent with a series of IRS Chief Counsel Advices [CCAs], the Proposed Rule is directed at addressing the taxation of the wellness indemnity arrangements that the IRS has been concerned with for years. However, the Proposed Rule goes much farther than previous CCAs and has serious implications for all group fixed indemnity and other similar types of insurance where premiums are paid on a pre-tax basis."  MORE >>

"The proposed rule would effectively reverse a 2018 tri-agency rule designed to expand the marketing and sale of STLDI to consumers. The administration also seeks public comment on the impact of other health insurance products and arrangements, namely specified-disease coverage, such as cancer-only or diabetes-only policies, and level-funded health plans."  MORE >>

"[1] Facility fees should be included in the information provided through the price comparison tool. [2] Advanced explanation of benefits likely to include facility fee estimates.... [3] [C]ost-sharing for services furnished by a nonparticipating provider, facility or provider of air ambulance services is considered cost-sharing for benefits provided outside of a plan's network for purposes of applying to an individual's maximum out-of-pocket limit ... [4] If a plan has a contractual relationship (whether direct or indirect) with a provider, facility, or provider of air ambulance services that sets forth the terms and conditions on which an item or service is provided, then such entity is considered participating for purposes the No Surprises Act and is also considered in-network for purposes of applying the maximum out-of-pocket limit under the ACA."  MORE >>

"Contrary to what many employers may think, not all employees are automatically entitled to leave time under the FMLA. Only about 50% of U.S. employees have FMLA coverage. Therefore, it is critical to understand what employees are covered under FMLA and when they are eligible to take leave."  MORE >>

"This local law amends the New York City Charter and directs the Mayor to establish an Office of Healthcare Accountability -- the first of its kind in the country. Among other things, the NYC Office of Healthcare Accountability will allow New Yorkers to compare costs charged by NYC hospitals for the same services."  MORE >>

"Contributions -- initially set at 0.7% and capped at 1.2% of wages up to the Social Security taxable wage base -- are evenly split between employers and employees. Contributions and benefits will start on Jan. 1, 2026. Covered employees may take up to 12 weeks of medical leave for a serious health condition and up to 12 weeks of family leave to bond with a new child, care for a family member, manage a qualifying exigency or address safety-related matters."  MORE >>

"There have already been a few examples of health plan fee cases, such as claims challenging the billing practice between insurers and their subcontractors or challenging commissions paid in connection with multi-employer plans. Recent advertisements by the class action plaintiffs' firm Schlichter Bogard soliciting current participants in particular companies' health plans relating to the fees they are being charged in those plans suggest the trend is continuing."  MORE >>