"Group health plan sponsors will need to determine whether they want to adopt this extended special enrollment period immediately, since Medicaid redeterminations are currently ongoing. Plan sponsors that decide to do so will need to coordinate this decision with their insurers, service providers, and (for self-insured plans) stop-loss carriers and will need to communicate the changes to employees and amend plan documents accordingly. "   MORE >>

"The proposed regulations reiterate the Departments' focus on mental health parity and underscore the importance of compliance for health plan sponsors. They also come after many plans have been subject to audit by the Departments which focused heavily on MHPAEA compliance, leaving plan sponsors frustrated at the lack of guidance and inconsistent application of MHPAEA."   MORE >>

"The mathematical test is likely to result in a plan's removal of prior authorization for outpatient MH/SUD benefits and concurrent reviews on inpatient MH/SUD benefits ... The relevant data evaluation requires TPA or insurer involvement ... [T]he proposed regulations, if finalized, would require plans to provide meaningful benefits for a treatment of a particular condition in all classifications if provided in one.... [T]here will be a substantial expansion of available network providers."   MORE >>

"[T]he new NQTL guidance is dense ... At the top of the list to revisit: [1] potentially improving mental health and substance use disorder treatment provider networks; [2] enhancing data collection efforts to better evaluate the parity in coverage; and [3] ensuring sufficient NQTL comparative analyses are produced."   MORE >>

"Review plan design for red flags.... Review plan service contracts for self-funded plans.... Confirm NQTL comparative analysis has been performed and request a copy.... Ask questions about your plan's network composition...."   MORE >>

"Your plan will satisfy the dependent coverage requirement if coverage is provided until a child attains 26 years of age.... [If] your company is an applicable large employer ... you could face potential employer shared responsibility penalties if you do not offer coverage to an employee's child through the last day of the month containing the child's 26th birthday. "   MORE >>

"Maine's PFML program applies to all employers who have at least one employee working in Maine (except the federal government). The payroll withholding of the employees' contributions is scheduled to begin on January 1, 2025, and according to the state's PFML website, the benefits will be available to eligible employees starting May 1, 2026."   MORE >>

"A federal trial court has dismissed a proposed class action lawsuit against an insurer for its health plans' exclusion of routine hearing examinations, hearing aids, and other hearing loss treatments. The participants alleged 'proxy' discrimination, intentional discrimination, and disparate impact under [ACA] Section 1557." [ E.S. v. Regence BlueShield , 2023 No. 17-1609 (W.D. Wash. Mar. 16, 2023)]   MORE >>

"A recent news release indicates that the [DOL] has an investigatory initiative focused on the issue of 'insurability' under life insurance benefits. This issue arises when insurance premiums are collected for ERISA insurance benefits but there is a failure to complete the necessary process of confirming evidence of insurability. The result is that the employee believes they have insurance coverage, but coverage is not available when sought because the evidence of insurability was never completed. The DOL views such failures as a potential breach of ERISA's fiduciary duties by either the insurer, the employer, or both."   MORE >>

"Cost sharing shifted from deductibles to copayments and coinsurance among enrollees in HSA-eligible health plans for a number of services impacted by IRS Notice 2019-45 .... IRS Notice 2019-45 appears to have had a negligible impact on overall cost sharing as a percentage of total spending on a number of services impacted by the notice. This may be due to the fact that employers were more likely to change cost sharing instead of eliminating it."   MORE >>

"While there is overall interest in taking a prescription weight loss drug, interest decreases substantially once people are asked if they would take a drug administered as routine injection (23% of all adults would still be interested), if it was not covered by their insurance (16%) ... or if they heard they may gain weight back after stopping use (14%). Most adults (80%) say that insurance companies should cover the cost of weight loss drugs for adults who are overweight or obese, while half of adults (53%) say insurance should cover the cost of these drugs for anyone who wants them to lose weight."   MORE >>

"Facility fee charges are becoming more common as hospital systems have accelerated their purchase of ambulatory settings and practices, leading to higher overall costs for outpatient care. Consumers bear the brunt of this, as they face increased out-of-pocket costs as well as higher premiums from these extra charges. Consumer exposure to these fees, coupled with the fact that these fees often appear unrelated to the level of care received, is contributing to the growing public perception that provider prices are too high."   MORE >>

"Overall, the proportion of policies that were consistent with the FDA label declined from 57.1% in 2017 to 45.1% in 2021; the proportion of policies that were more restrictive than the FDA label increased from 39.5% to 51.7%. The proportion of policies excluding drug coverage remained roughly constant (3.4% in 2017; 3.2% in 2021). Trends in coverage restrictiveness varied across plans. For 13 plans, the proportion of policies with restrictions increased over time, while for 4 plans it declined."   MORE >>

"By adopting best practices such as using a consistent format, avoiding jargon, distinguishing facts from opinions, and regular reviews, committees can significantly improve the quality of their minutes. Furthermore, ensuring secure storage, whether digital or physical, for a substantial duration is crucial for long-term reference and legal protection."   MORE >>