"[S]everal provisions of both the interim final and final regulations, as well as related agency guidance, have been vacated in a series of cases brought by an association of health care providers. In response, the agencies recently issued proposed regulations addressing IDR fee issues raised by the litigation and, among other things, partially shut down and reopened the federal IDR portal multiple times. The agencies now propose additional regulations to adjust the IDR process and change the fee structure. Here are highlights."  MORE >>

"The requirement to make the attestation applies to insurers and group health plans, including ERISA plans, non- federal governmental plans, and church plans subject to the Code, regardless of grandfathered or grandmothered status. Plans providing solely excepted benefits, health reimbursement arrangements (HRAs), and other account- based plans need not submit attestations."  MORE >>

"[The Illinois] Act does not apply to any employer already covered by a municipal or county ordinance that requires employers to provide any form of paid leave -- including paid sick leave -- to its employees.... California employers in cities with local sick leave ordinances should still be mindful of complying with both the state and local sick leave laws.... [U]nder some local laws, frontloading paid sick time does not eliminate carryover obligations and/or the local ordinance may impose a higher annual usage limit (if any at all)."  MORE >>

"The DOL has long taken the position that cross-plan offsetting violates ERISA. Relatively few courts have considered cross-plan offsetting issues, and while at least one did conclude that the practice violates ERISA, other cross-plan offsetting cases have been decided on different grounds."   MORE >>

"The International Brotherhood of Electrical Workers, the International Brotherhood of Teamsters and dozens more unions and multi-employer organizations recently sent a letter to Senate lawmakers asking them to shield employer health plans from PBM legislation.... Their letter doesn't lay out the specific policies they're worried that lawmakers are considering, and union officials declined to elaborate. But recent state efforts to regulate PBMs could provide insight into unions' concerns."  MORE >>

"HHS began investigating the BA in April 2019 after receiving a breach notification from the BA indicating that its network server had been infected by Gandcrab ransomware in April 2017, resulting in unauthorized access to the network. The BA did not detect the attack until more than a year-and-a-half later -- when the ransomware encrypted its data in December 2018."  MORE >>

"State-level laws providing the right to earn paid sick days corresponded with a significant increase in access to paid sick days across the country. Overall, 78% of private-sector workers currently have access to paid sick days, up from 63% in 2010. Across the country, the share of the lowest-wage workers with access to paid sick time nearly doubled between 2010 and 2023, from 20% to 39%. While this marks progress, it still means 61% of the lowest-wage workers do not have access to paid sick time."  MORE >>